Turner v. Rogers

Turner (plaintiff) was repeatedly held in civil contempt over three years for failing to pay child support to Rogers (defendant), and at his fifth and sixth contempt hearings — held without either party represented by counsel — he explained his past drug addiction and broken back but recent efforts to find employment, yet the court sentenced him to 12 months in jail without any express finding on his ability to pay or follow-up questioning about his finances. Turner appealed with pro bono counsel arguing a right to appointed counsel given the risk of incarceration, and the South Carolina Supreme Court rejected that claim after he'd already served his sentence, prompting Supreme Court review.