This year marked the sixtieth anniversary of Gideon v. Wainwright, the seminal case in which the Supreme Court of the United States held that the Sixth and Fourteenth Amendments to the Constitution guarantee a right to court-appointed counsel to indigent criminal defendants charged with serious offenses. Very few would argue with that basic proposition today. Instead, the contemporary debate is whether to recognize a “civil Gideon,” i.e. a right to court-appointed counsel for indigent civil litigants.