John P. Gross,
Too Poor to Hire a Lawyer but Not
Indigent: How States Use the Federal
Poverty Guidelines to Deprive
Defendants of their Sixth Amendment
Right to Counsel, 70 Wash. & Lee L. Rev. 1173
(2013).
Available at: https://scholarlycommons.law.wlu.edu/wlulr/vol70/iss2/11