The United States Supreme Court has held that the sixth and fourteenth amendments do not require a state to provide counsel for an indigent defendant charged with a crime for which imprisonment upon conviction is authorized but not imposed.
Scott v. Illinois, 99 S. Ct. 1158 (1979).
Patricia T. Galvin,
Constitutional Law - Sixth Amendment - Indigent Criminal Defendants - Right to Assigned Counsel - Misdemeanors,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol18/iss2/7