777

Right to Counsel

A person in criminal or civil contempt may not be sentenced to a term of imprisonment unless he was afforded the right to counsel at the contempt proceeding. See Argersinger v. Hamlin, 407 U.S. 25 (1972); In re Rosahn, 671 F.2d 690, 697 (2d Cir. 1982); In re Di Bella, 518 F.2d 955 (2d Cir. 1975); In re Kilgo, 484 F.2d 1215 (4th Cir. 1973); Henkel v. Bradshaw, 483 F.2d 1386 (9th Cir. 1973). [cited in USAM 9-39.000]