May the court require counsel to represent a person without compensation for an offense for which a person does not have the right to appointed counsel?

A court may have the inherent authority to do so in some circumstances, but the limits of the authority have not been tested in North Carolina. In one case, the court held that counsel representing a defendant sentenced to death could be required, without compensation, to file a certiorari petition to the U.S. Supreme Court. See In re Hunoval, 294 N.C. 740 (1977) (rejecting attorney’s argument that he was not an eleemosynary institution—that is, a charitable institution [cert. petitions are now compensated as provided in the IDS rules]). The extent to which the North Carolina courts would extend this ruling to other contexts is unclear. Requiring counsel to proceed without compensation has been the subject of challenges in other states, a subject beyond the scope of this discussion.