In Lassiter v. Dep't of Social Services, 452 U.S. 18 (1981), the Court considered whether the federal due process clause required appointment of counsel for indigent parents in every parental termination proceeding. Lassiter, 452 U.S. at 31. The Court balanced the Eldridge factors (Mathews v. Eldridge) against each other and against the presumption that an indigent litigant is entitled to appointed counsel only in cases in which deprivation of physical liberty is involved. Id. In Lassiter, the Court held that the Constitution does not mandate the appointment of counsel for indigent parents in every proceeding to terminate parental rights. Id. at 32. Instead, under the federal due process clause, a district court, in the exercise of sound judicial discretion and subject to review on appeal, must decide whether, under the circumstances of the case, due process requires the appointment of counsel for an indigent parent. Id. The United States Supreme Court addressed whether an indigent civil litigant has a due process right to court-appointed counsel where the loss of parental rights was at stake. The Court made clear that resolution of the issue did not turn on whether the "proceedings may be styled 'civil' and not 'criminal.'" Id. at 25. Rather, it noted that "it is a litigant's interest in personal freedom and not simply the special Sixth and Fourteenth Amendments' right to counsel in criminal cases, which triggers the right to appointed counsel . . . ." Id. The Court cited In re Gault, 387 U.S. 1, 36-37 (1967), as authority for its conclusion, noting that "the pre-eminent generalization that emerges from [the United States Supreme] Court's precedents on an indigent's right to appointed counsel is that such a right has been recognized to exist only where the litigant may lose his physical liberty if he loses the litigation." Lassiter, 452 U.S. at 25. In In re Gault, which established the core principle of the Lassiter holding, court-appointed counsel was found to be "essential" in a civil delinquency proceeding because it carried "with it the awesome prospect of incarceration in a state institution." 387 U.S. at 36-37. The proceeding's technical classification as "non-criminal" was of no consequence. Id. at 27. Thus, in both Lassiter and Gault, the right to counsel was triggered by a litigant's risk of actual incarceration.