The U.S. Supreme Court case Michael D. Turner v. Rebecca L. Rogers et al., 2010, revolved around the issue of whether an indigent defendant has a constitutional right to counsel at a civil contempt hearing that could result in his incarceration for failure to pay child support. The petitioner, Michael Turner, argued that he was denied due process when he was not provided with legal representation during proceedings which resulted in him being jailed for non-payment of child support. However, the court ruled against him by a 5-4 majority stating that while defendants have a constitutional right to counsel in criminal cases where their liberty is at stake under the Sixth Amendment; this does not automatically extend to civil cases like child-support hearings even if jail time may be imposed as punishment for non-compliance.

In the dissenting opinion for the case of Michael D. Turner v. Rebecca L. Rogers et al., Justice Clarence Thomas argued that due process does not require a state to provide counsel at civil contempt proceedings, even when those proceedings may result in incarceration. He contended that historically, there was no right to appointed counsel in civil cases and this tradition should be upheld as it is consistent with constitutional requirements of due process. Furthermore, he stated that providing an attorney would not necessarily improve the fairness or accuracy of these proceedings because they are typically straightforward determinations about whether someone has violated a court order and if so, what sanction is appropriate given their ability to comply with said order.