The following excerpt is from Barbour v. Dorna Sports USA, 116 F.3d 1485 (9th Cir. 1997):
Finally, Barbour contends that she was denied effective assistance of counsel because her counsel did not request a jury trial. A plaintiff in a civil case generally has no federal constitutional right to effective assistance of counsel. See Nicholson v. Rushen, 767 F.2d 1426, 1427 (9th Cir.1985) (per curiam).
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