This comment argues that when an individual is targeted by a civil gang injunction that interferes with that individual's family relationships, due process requires the appointment of counsel for that individual. This comment does not argue that civil gang injunctions should be prohibited, or even that civil gang injunctions should not be able to enjoin family members from seeing each other in public. Part I discusses the problem of gangs and how civil gang injunctions have emerged to combat them. Part II explores factors considered for the appointment of counsel in civil cases and why family relationships put a personal interest at stake that warrants such appointment. Finally, Part III explores how the government's interests and the risk of erroneous decisions in civil gang injunction proceedings that interfere with family relationships further warrant the appointment of counsel.
Family Ties or Criminal Contacts: A Case for the Appointment of Counsel in Civil Gang Injunction Proceedings That Affect Family Relationships, 39 Golden Gate U. L. Rev.