Epstein Secrets

83, 86 (1963) (holding prosecution's withholding of the confession of defendant's confederate violated defendant's due process rights). 7 Gideon v. Wainwright, 372 U.S. 335, 342 (1963) (extending Sixth Amendment right to assistance of counsel to indigent state criminal defendants); Powell v. Alabama, 287 U.

attorneys hold elective offices; if their constituents are unsatisfied, they are free to express their feelings at the voting polls."); cf. Chenev v. U.S. Dist. Court, 542 U.S. 367, 386 (2004) ("The decision to prosecute a criminal case ... is made by a publicly accountable prosecutor."). For discussion of this poi

in [the CVRA] was agreed to."). °! 150 Cong. Rec. H8208-09 (daily ed. Oct. 6, 2004). °2 150 Cong. Rec. $10910 (daily ed. Oct. 9, 2004). % Kenna v. U.S. Dist. Court for the Cent. Dist. of Cal., 435 F.3d 1011, 1015-16 (9th Cir. 2006) (internal quotations and citations omitted); accord United States v. Sharp, 463 F

ermits the court in both civil and criminal cases to "request an attorney to represent any person unable to afford counsel." 49° And before Gideon v. Wainwright, *°° courts could request 45 Td. 46 Td. 47 Tn possible response to such concerns as I raise here, the Advisory Committee modified the Advisory Comm

nd criminal cases. 3!! While these cases do not directly involve [*913] appointment of counsel for crime victims, their principles 309 Cf. Gideon v. Wainwright, 372 U.S. 335, 344 (1963) (discussing "fairness" to the defendant as a reason for recognizing a right to appointed counsel). 310 150 Cong. Rec. S426

the National Crime Victims Law Institute and other legal clinics for victims). w 8 See Gillis & Beloof, supra note 314, at 692. 319 See Mallard v. U.S. Dist. Court, 490 U.S. 296, 307 & n.8 (1989) (leaving open the question of whether federal courts possess the inherent authority to require counsel to provide leg