The following excerpt is from USA. v. Budell, 187 F.3d 1137 (9th Cir. 1999):
In United States v. LaFromboise, 836 F.2d 1149, (8th Cir. 1988), the court viewed the constitutional right to counsel in the same light as the right to periodic adversary hearings was viewed in Hickey, and held that due process did not require continuous representation by counsel after the initial commitment hearing "if the hospital administration acts independently" in preparing periodic reports. 10 Id. at 1152.
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