Hodges v. Hodges

EAGLES, Judge.

Defendant’s first assignment of error is that the trial court erred in not appointing counsel for defendant at the civil con tempt hearing. We find no error. In reaching this result, we are bound by the North Carolina Supreme Court’s holding in Jolly v. Wright, 300 N.C. 83, 265 S.E. 2d 135 (1980), that (1) the Sixth Amendment right to counsel is inapplicable to civil contempt because that right is confined to criminal proceedings and (2) due process does not guarantee appointment of counsel in nonsupport civil contempt proceedings.

The Sixth Amendment right to counsel is…