context: Under certain circumstances, a petitioner may be forced to proceed without counsel. This might be warranted if the petitioner were not a minor and had explicitly waived his right to counsel, or delayed the hearing in bad faith, or sat on his right to obtain counsel.
citation_a.signal: see
citation_a.identifier: 577 F.2d 577, 579
citation_a.parenthetical: finding abuse of discretion and noting absence of indication that alien was delaying hearing in bad faith in not yet having obtained counsel
citation_a.sentence: See Colindres-Aguilar v. INS, 819 F.2d 259 (9th Cir.1987) (finding due process violation where without questioning him IJ deemed alien who had received previous continuance to obtain counsel to be proceeding pro se when he showed up at reconvened hearing without his new counsel); Castro-Nuno v. INS, 577 F.2d 577, 579 (9th Cir.1978) (finding abuse of discretion and noting absence of indication that alien was delaying hearing in bad faith in not yet having obtained counsel); cf. Vides-Vides v. INS, 783 F.2d 1463, 1470 (9th Cir.1986) (finding no due process violation where adult alien’s “failure to obtain counsel after four months and two continuances makes apparent that he simply was unable to secure counsel at his own expense.”).
citation_b.signal: cf.
citation_b.identifier: 783 F.2d 1463, 1470
citation_b.parenthetical: finding no due process violation where adult alien's "failure to obtain counsel after four months and two continuances makes apparent that he simply was unable to secure counsel at his own expense."
citation_b.sentence: See Colindres-Aguilar v. INS, 819 F.2d 259 (9th Cir.1987) (finding due process violation where without questioning him IJ deemed alien who had received previous continuance to obtain counsel to be proceeding pro se when he showed up at reconvened hearing without his new counsel); Castro-Nuno v. INS, 577 F.2d 577, 579 (9th Cir.1978) (finding abuse of discretion and noting absence of indication that alien was delaying hearing in bad faith in not yet having obtained counsel); cf. Vides-Vides v. INS, 783 F.2d 1463, 1470 (9th Cir.1986) (finding no due process violation where adult alien’s “failure to obtain counsel after four months and two continuances makes apparent that he simply was unable to secure counsel at his own expense.”).