The following excerpt is from U.S. v. 30.64 Acres of Land, More or Less, Situated in Klickitat County, State of Wash., 795 F.2d 796 (9th Cir. 1986):
Federal courts also frequently receive motions for counsel in actions for habeas corpus and other postconviction relief. See, e.g., 28 U.S.C. Secs. 2241, 2254 and 2255 (1982). Although such actions are technically civil, discretionary appointment of counsel for such suits is specifically authorized by the Criminal Justice Act, 18 U.S.C. Sec. 3006A(g) (1982), because of the suits' close relation to criminal proceedings. See also McClain v. Manson, 343 F.Supp. 382, 383 (D.Conn.1972) (counsel appointed under 18 U.S.C. 3006A to prosecute a 42 U.S.C. Sec. 1983 action that was essentially habeas corpus in nature).
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