In State v. Pultz, 206 Wis. 2d 112, 132, 556 N.W.2d 708 (1996), a court had permanently enjoined Dale Pultz from "engaging in particular activities at Milwaukee medical clinics." Id. at 115. Apparently, Pultz continued his activities because he was personally served with a notice and motion for contempt. See id. at 116. Before the hearing on the contempt, he was arrested. See id. He missed his court date because he was sitting in jail. See id. When he finally appeared, he complained to the judge that he had not had a chance to hire a lawyer because of his incarceration. See id. at 116-17. The trial court rebuffed the contention and found him in contempt. See id. 118. The supreme court reversed. See id. at 115. It held that when an unrepresented litigant comes before the court on a remedial contempt motion, and his or her liberty is threatened, the court must inform the defendant of the right to an attorney and the right to appointed counsel if he or she cannot afford one. See id. at 129. The court said that this was a "blanket rule." See id.