Nicole K. v. Stigdon

Dist. Ct. did not err in dismissing on abstention grounds lawsuit filed by plaintiff-children participating in State of Indiana abuse/neglect proceedings, where Dist. Ct. found that state court should resolve plaintiffs' contention that U.S. Constitution entitled them to appointment of legal counsel, where State of Indiana automatically appoints legal counsel for parents in said proceedings. Unless there is principle requiring counsel in every case, state-court's procedures suffice to allow individuals to argue that lawyer is required in any particular case. As such, because children are not automatically entitled to lawyer in instant civil state-court proceeding, it would be inappropriate for federal court to resolve appointment-of-counsel question in any of plaintiffs' proceedings. Accordingly, state court may either appoint counsel, if it seems necessary, or explain why said appointment is unnecessary, and any ruling can potentially be reviewed by U.S. Supreme Court, if state judiciary ultimately rejects plaintiffs' constitutional arguments.