California Reporter 1985; 213: 529-532
The California Court of Appeal ordered that the indigent subject of a public conservatorship and involuntary confinement to a mental health facility be given a complete transcript of the conservatorship proceeding without charge. The Court held that, although the commitment proceedings were civil, persons confined in mental facilities are deprived of their personal freedom, making their confinement no less incarceration than after a criminal proceeding. Constitutional rights of due process include not only the right to appointment of appellate counsel, but also the right to reasonably necessary ancillary services, of which a transcript of the proceedings is a part. (KIE abstract)
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