Expanding The Civil Privilege Of Being Represented By Counsel Through The Presumed Prejudice Doctrine

On the fiftieth anniversary of Gideon v Wainwright,\u27 many scholars are examining 2 the promise to not ration justice 3 by requiring counsel to be appointed for the indigent for State crimes. 4 Yet, other scholars are trying to expand Gideon\u27s promise to all civil law matters,5 including immigration. Providing free appointed immigration counsel for representation in secretive 7 civil immigration removal proceedings would be ideal. However, for respondents who are subjected to the mandatory deportation consequences of their *9. convictions, immigration representation is impractical and serves little purpose.\u27 0 A better approach is to have criminal counsel simultaneously provide immigration representation by creating a record of conviction to avoid removal proceedings in their entirety