Indigent parents sought classwide relief, alleging that they had been jailed for failing to pay child support after contempt proceedings in which Department lawyers appeared. The Supreme Court of Georgia held that federal due process does not categorically require appointed counsel in child-support contempt proceedings, even when incarceration is possible. It explained that the need for counsel depends on the circumstances of each proceeding, defeating commonality, typicality, and classwide injunctive or declaratory relief. The Court affirmed the reversal of class certification; Justice Benham concurred in part and dissented in part, concluding that the class could proceed on the distinct state constitutional claim.