California, United States of America
The following excerpt is from Gomez v. Cano, G054394 (Cal. App. 2018):
entitled to appointment of counsel at public expense. The appellate court in Chevalier v. Dubin, supra, 104 Cal.App.3d at page 979, which involved a civil case and money damages, distinguished Salas, holding: "The fact that the right of effective counsel is available to a defendant in a paternity case does not mean that it is also available to a defendant in a punitive damage case, merely because both are civil actions. Unlike a paternity case, a punitive damage case involves only a monetary judgment. Unlike a paternity case, a punitive damage case cannot expose a defendant to a possible deprivation of his liberty. Unlike a paternity case, a punitive damage case does not involve state participation nor a substantial state interest." The Chevalier court further stated: "Moreover, civil suits involving punitive damages are essentially private matters between the litigants. Each litigant selects his own counsel, for better or for worse." (Ibid.)
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