<P> In all criminal prosecutions, the accused shall enjoy the right...to have the Assistance of Counsel for his defence . </P> <P> The assistance of counsel clause includes, as relevant here, five distinct rights: the right to counsel of choice, the right to appointed counsel, the right to conflict - free counsel, the effective assistance of counsel, and the right to represent oneself pro se . </P> <P> A defendant does not have a Sixth Amendment right to counsel in any civil proceeding, including a deportation hearing (even though deportability is often a collateral consequence of criminal conviction). However, as described below, there are certain civil proceedings where parties have a right to appointed counsel; such a right is pursuant to the Fourteenth Amendment's due process or equal protection clause, a state constitution's due process or equal protection clause, or a federal / state statute . </P> <P> Subject to considerations such as conflicts of interest, scheduling, counsel's authorization to practice law in the jurisdiction, and counsel's willingness to represent the defendant (whether pro bono or for a fee), criminal defendants have a right to be represented by counsel of their choice . The remedy for erroneous deprivation of first choice counsel is automatic reversal . </P>

When is a person entitled to counsel pursuant to the 6th amendment