never interviewed him, did not seek to have him participate at the hearing, offered no evidence at the hearing to oppose the petition, cross-examined only one witness (which permitted th from Civil Commitment, 118 Yale L.J. 272, 286 (2008) (“Frueh”). ¶30 Because the right to effective assistance of counsel is a due process question, we must turn to Mathews. Given the significant liberty interests involved, the substantial risk of error without a competent attorney, and the government interest that patients are represented, the Due Process Clause of the Fourteenth Amendment requires that a civil commitment patient receive effective assistance of counsel. In re Beverly, 342 So.2d 481, 489 (Fla.1977); Matter of Carmody, 274 Ill.App.3d 46, 210 Ill.Dec. 782, 653 N.E.2d 977, 983 (1995) (<HOLDING>); In re Mental Health of K.G.F., 306 Mont. 1,
holding that a parents statutory right to counsel in termination proceedings guarantees the right to effective counsel holding that the sixth amendment right to counsel embodies the right to effective assistance of counsel holding that the statutory right to counsel at a civil commitment hearing implicitly includes the right to the effective assistance of that counsel recognizing that a criminal defendants right to counsel is the right to the effective assistance of counsel recognizing constitutional right to effective counsel