Honor v. Yamuchi
In Honor v. Yamuchi, 307 Ark. 324, 820 S.W.2d 267 (Ark. 1991) the court held that due process requires that a person subject to a civil commitment hearing who chooses to proceed without counsel must do so intelligently, or the "waiver" is invalid. Id. at 270-71.
"To determine that long-term custody is appropriate because the individual lacks the capacity to comprehend impending dangers, finding at the same time there has been a knowing and intelligent waiver, is patently inconsistent." Id. at 271.