witness to testify about the need for mental health treatment) and made no closing argument. Petitioner conceded at oral argument on appeal that Appellant has a right to effective assistance of counsel. We agree that Appellant has a right to effective assistance of counsel and on this record, remand to the trial court to determine if counsel failed to meet his obligations under A.R.S. § 36-537. ¶ 29 Under A.R.S. § 36-528(D) (2009), - 535(A), -536(A), and -539(B) (Supp.2010), a patient facing a civil commitment proceeding is entitled to assistance of counsel. The patient’s rights are found in the Due Process Clause of the Fourteenth Amendment; Afi-ele 2, Section 4, of the Aizona Constitution; and Arizona’s civil commitment statute. MH-2008-000867, 225 Ariz. at 181, ¶ 9, 236 P.3d at 408 (<HOLDING>); Joseph Frueh, Note, The Anders Brief in
holding that the confrontation clause does not apply to the sentencing hearing holding that any confrontation right is found in the fourteenth amendments due process clause not the confrontation clause of the sixth amendment holding that the confrontation clause is applicable to the states through the fourteenth amendment holding that the sixth amendment right of confrontation applies to all three phases of the capital trial and that the admission of  hearsay statements of codefendants in the penalty phase violated the confrontation clause holding that in reviewing confrontation clause challenge appellate courts must first determine whether the confrontation clause is implicated