University of Baltimore Law Review


While the United States Supreme Court has developed two distinct tests to determine when an indigent has a right to counsel in a judicial proceeding, it has never specifically considered whether an indigent accused enjoys this right in an extradition proceeding. Courts which have addressed the issue have refused to recognize this right without providing an adequate discussion of the Supreme Court's tests. This comment examines the nature of the extradition process, applies the two constitutional tests, and concludes that no right to a pointed counsel exists under either the sixth amendment or the due process clause of the Constitution.

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