Deportation is a significant deprivation of liberty--both scholars and courts have likened it to criminal punishment. In fact, with the passage of the Illegal Immigrant Reform and Immigration Reform Act in 1996, Congress expanded the grounds for deportation while narrowing the avenues for relief. Moreover, immigration law is notoriously complex, as are the deportation proceedings themselves. These adjudicatory hearings incorporate many of the formal procedural protections adopted by courts of law. Yet non-citizens, who often have little understanding of the American legal system, have no right to appointed counsel. In light of the significant interests at stake, the complexity of the process, and the evolving nature of the law, the right to appointed counsel is necessary to ensure that the dictates of due process are satisfied.