This Note will provide a history of a civil contemnor's right to appointed counsel in North Carolina by reviewing the statutory and judicial history prior to McBride v. McBride, primarily through a study of the North Carolina Supreme Court holding in Jolly v. Wright. Next, this Note will look at the law outside of North Carolina which effected the holding in McBride. Next, this Note will examine the court's ruling in McBride, and discuss the altered judicial reasoning which led to the court's holding. Finally, this Note will address the ramifications of McBride, and conclude with a discussion of the decision's effects and the questions it left unanswered.
Kurt F. Hausler, The Right to Appointment of Counsel for the Indigent Civil Contemnor Facing Incarceration for Failure to Pay Child Support - McBride v. McBride, 16 Campbell L. Rev. 127 (1994).