HARRIS, Justice.
Does an indigent paternity defendant have a constitutional right to counsel at public expense? The trial court held he does not and we agree.
These proceedings were initiated by the State under the uniform support of dependents law. Iowa Code ch. 262A (1979). The relator alleged defendant was the father of her daughter and should be required to support the child during minority and to reimburse the state for support received under the aid to dependent children program (ADC). By mandate of a federal statute the state must commence paternity proceedings against a putative father whenever a mother applies for ADC and it is determined the father has abandoned the mother and child. 42 U.S.C. § 654(4) (1976 & Supp. III). Any support payments imposed in the proceeding are assigned by the mother to the state so long as she receives ADC support. § 252A.13. Thus the state would at present receive any support payments required of the defendant and can be said to have initiated these proceedings.
Defendant appeared pro se and filed an answer denying the allegations in the petition. He obtained the assistance of Attorney Robert F. Heimer for the limited purpose of obtaining counsel at public expense to represent him further. He asserted the right to counsel arises under the federal and state constitutions. The request for appointment of counsel alleged defendant was indigent within the meaning of Iowa Code section 336A.4 and was unable to retain counsel without threatening his ability to provide economic necessities for his family-
In denying the defendant’s motion for appointment of counsel the trial court made no finding regarding defendant’s indigency. It simply found this is a civil proceeding and that section 336A.4, defining indigency, “applies to criminal actions only.” For purposes of reviewing the trial court holding we assume, without deciding, that defendant is indigent.
I. Because the proceeding is and must be brought to recoup funds for the State it is a “state action” for purposes of the due process clause. U.S. Const.amend. V; Iowa Const, art. I, § 9. Snodgrass must be afforded due process.
Defendant’s due process contention arises from principles enunciated in Morrissey v. Brewer, 408 U.S. 471, 92 S.Ct. 2593, 33 L.Ed.2d 484 (1972). If an individual is threatened with State action which will deprive him of life, liberty or property, he is entitled to due process. What process is due depends upon the nature of the government function and individual interest involved.
[742]*742State v. Crimme, 274 N.W.2d 331, 336 (Iowa 1979).
Due process calls for “a meaningful opportunity to be heard.” Boddie v. Connecticut, 401 U.S. 371, 377, 91 S.Ct. 780, 785, 28 L.Ed.2d 113, 118 (1971); Auxier v. Woodward State Hosp.-Sch., 266 N.W.2d 139, 142-43 (Iowa 1978).
The trial court was wrong in rejecting Snodgrass’s application on the basis of a distinction between civil and criminal proceedings. Some proceedings which are called civil require appointment of counsel so it is not a question of labeling the action criminal or civil. The right to counsel has more to do with a person’s stake in the proceeding and the practical effect of the outcome. Lassiter v. Dept. of Social Services, 452 U.S. 18, 24, 101 S.Ct. 2153, 2158, 68 L.Ed.2d 640, 648-49 (1981).
Lassiter is helpful here for what it explains and is controlling for what it rejects. Due process, it points out, “has never been, and perhaps can never be, precisely defined.” 452 U.S. at 24, 101 S.Ct. at 2158, 68 L.Ed.2d at 648. Fundamental fairness is a part of the requirement and the requirement varies according to the interests at stake. Id. The court stated: “The preeminent generalization that emerges from this court’s precedents on an indigent’s right to appointed counsel is thát such a right has been recognized to exist only where the litigant may lose his physical liberty if he loses the litigation.” Id. (Emphasis added.) Fundamental fairness presumes that an indigent’s right to appointed counsel arises “only when, if he loses, he may be deprived of his physical liberty. It is against this presumption that all the other elements in the due process decision must be measured.” Id. at 27, 101 S.Ct. at 2159, 68 L.Ed.2d at 649.
In considering an indigent’s claim of the right to appointed counsel, the court balances the Eldridge factors, three elements originally defined in Mathews v. Eldridge, 424 U.S. 319, 335, 96 S.Ct. 893, 903, 47 L.Ed.2d 18, 33 (1976). It then “set[s] their net weight in the scales against the presumption that there is a right to appointed counsel only where the indigent, if he is unsuccessful, may lose his personal freedom.” Id. at 27, 101 S.Ct. at 2159, 68 L.Ed.2d at 649. The three Eldridge factors are: (1) the private interests at stake, (2) the governmental interest, and (3) the risk that the procedures used will lead to an erroneous decision and the probable value, if any, of additional safeguards.
Lassiter was a proceeding to terminate a parental relationship. The court determined that the net weight of the Eldridge factors would not in every termination proceeding overcome the presumption that no right to counsel exists unless one’s physical liberty is threatened. Due process determinations were left to a case by case approach. Id. at 32, 101 S.Ct. at 2162, 68 L.Ed.2d at 652.
II. Snodgrass’s interest in the proceedings are substantial but, we think, less than those of a parent in a termination proceeding. Although he claims otherwise his liberty is not immediately involved. He argues that one ramification of a finding of paternity would be possible incarceration in a later contempt proceeding for failure to make support payments. Iowa Code § 252A.3(1) (1981). It is true that the finding of paternity in these proceedings would be binding in any subsequent contempt proceeding involving the question. If Snod-grass willfully fails to make ordered support payments he is subject to civil contempt and incarceration may result. § 252A.6(13). In such a contempt hearing, of course, Snodgrass is entitled to counsel. We have recognized a right to counsel in a hearing that might directly result in incarceration. McNabb v. Osmundson, 315 N.W.2d 9, 14 (Iowa 1982).
Nevertheless it is only when Snodgrass would willfully ignore a court order that he would become threatened with a finding of contempt and a potential loss of liberty. Snodgrass’s interest here does not differ significantly from that of an indigent defendant in a myriad of other civil proceedings. For example, the willful failure or refusal to make child support or alimony [743]*743payments could lead to a contempt proceeding. The violation of an injunction often results in a finding of contempt.
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HARRIS, Justice.
Does an indigent paternity defendant have a constitutional right to counsel at public expense? The trial court held he does not and we agree.
These proceedings were initiated by the State under the uniform support of dependents law. Iowa Code ch. 262A (1979). The relator alleged defendant was the father of her daughter and should be required to support the child during minority and to reimburse the state for support received under the aid to dependent children program (ADC). By mandate of a federal statute the state must commence paternity proceedings against a putative father whenever a mother applies for ADC and it is determined the father has abandoned the mother and child. 42 U.S.C. § 654(4) (1976 & Supp. III). Any support payments imposed in the proceeding are assigned by the mother to the state so long as she receives ADC support. § 252A.13. Thus the state would at present receive any support payments required of the defendant and can be said to have initiated these proceedings.
Defendant appeared pro se and filed an answer denying the allegations in the petition. He obtained the assistance of Attorney Robert F. Heimer for the limited purpose of obtaining counsel at public expense to represent him further. He asserted the right to counsel arises under the federal and state constitutions. The request for appointment of counsel alleged defendant was indigent within the meaning of Iowa Code section 336A.4 and was unable to retain counsel without threatening his ability to provide economic necessities for his family-
In denying the defendant’s motion for appointment of counsel the trial court made no finding regarding defendant’s indigency. It simply found this is a civil proceeding and that section 336A.4, defining indigency, “applies to criminal actions only.” For purposes of reviewing the trial court holding we assume, without deciding, that defendant is indigent.
I. Because the proceeding is and must be brought to recoup funds for the State it is a “state action” for purposes of the due process clause. U.S. Const.amend. V; Iowa Const, art. I, § 9. Snodgrass must be afforded due process.
Defendant’s due process contention arises from principles enunciated in Morrissey v. Brewer, 408 U.S. 471, 92 S.Ct. 2593, 33 L.Ed.2d 484 (1972). If an individual is threatened with State action which will deprive him of life, liberty or property, he is entitled to due process. What process is due depends upon the nature of the government function and individual interest involved.
[742]*742State v. Crimme, 274 N.W.2d 331, 336 (Iowa 1979).
Due process calls for “a meaningful opportunity to be heard.” Boddie v. Connecticut, 401 U.S. 371, 377, 91 S.Ct. 780, 785, 28 L.Ed.2d 113, 118 (1971); Auxier v. Woodward State Hosp.-Sch., 266 N.W.2d 139, 142-43 (Iowa 1978).
The trial court was wrong in rejecting Snodgrass’s application on the basis of a distinction between civil and criminal proceedings. Some proceedings which are called civil require appointment of counsel so it is not a question of labeling the action criminal or civil. The right to counsel has more to do with a person’s stake in the proceeding and the practical effect of the outcome. Lassiter v. Dept. of Social Services, 452 U.S. 18, 24, 101 S.Ct. 2153, 2158, 68 L.Ed.2d 640, 648-49 (1981).
Lassiter is helpful here for what it explains and is controlling for what it rejects. Due process, it points out, “has never been, and perhaps can never be, precisely defined.” 452 U.S. at 24, 101 S.Ct. at 2158, 68 L.Ed.2d at 648. Fundamental fairness is a part of the requirement and the requirement varies according to the interests at stake. Id. The court stated: “The preeminent generalization that emerges from this court’s precedents on an indigent’s right to appointed counsel is thát such a right has been recognized to exist only where the litigant may lose his physical liberty if he loses the litigation.” Id. (Emphasis added.) Fundamental fairness presumes that an indigent’s right to appointed counsel arises “only when, if he loses, he may be deprived of his physical liberty. It is against this presumption that all the other elements in the due process decision must be measured.” Id. at 27, 101 S.Ct. at 2159, 68 L.Ed.2d at 649.
In considering an indigent’s claim of the right to appointed counsel, the court balances the Eldridge factors, three elements originally defined in Mathews v. Eldridge, 424 U.S. 319, 335, 96 S.Ct. 893, 903, 47 L.Ed.2d 18, 33 (1976). It then “set[s] their net weight in the scales against the presumption that there is a right to appointed counsel only where the indigent, if he is unsuccessful, may lose his personal freedom.” Id. at 27, 101 S.Ct. at 2159, 68 L.Ed.2d at 649. The three Eldridge factors are: (1) the private interests at stake, (2) the governmental interest, and (3) the risk that the procedures used will lead to an erroneous decision and the probable value, if any, of additional safeguards.
Lassiter was a proceeding to terminate a parental relationship. The court determined that the net weight of the Eldridge factors would not in every termination proceeding overcome the presumption that no right to counsel exists unless one’s physical liberty is threatened. Due process determinations were left to a case by case approach. Id. at 32, 101 S.Ct. at 2162, 68 L.Ed.2d at 652.
II. Snodgrass’s interest in the proceedings are substantial but, we think, less than those of a parent in a termination proceeding. Although he claims otherwise his liberty is not immediately involved. He argues that one ramification of a finding of paternity would be possible incarceration in a later contempt proceeding for failure to make support payments. Iowa Code § 252A.3(1) (1981). It is true that the finding of paternity in these proceedings would be binding in any subsequent contempt proceeding involving the question. If Snod-grass willfully fails to make ordered support payments he is subject to civil contempt and incarceration may result. § 252A.6(13). In such a contempt hearing, of course, Snodgrass is entitled to counsel. We have recognized a right to counsel in a hearing that might directly result in incarceration. McNabb v. Osmundson, 315 N.W.2d 9, 14 (Iowa 1982).
Nevertheless it is only when Snodgrass would willfully ignore a court order that he would become threatened with a finding of contempt and a potential loss of liberty. Snodgrass’s interest here does not differ significantly from that of an indigent defendant in a myriad of other civil proceedings. For example, the willful failure or refusal to make child support or alimony [743]*743payments could lead to a contempt proceeding. The violation of an injunction often results in a finding of contempt. A requirement of appointed counsel in paternity proceedings would inevitably lead to a requirement of appointed counsel for indigent defendants in other actions which might one day form the basis of a contempt proceeding. A paternity finding seems constitutionally indistinguishable from a vast array of court orders the violation of which might subject one to contempt.
III. The interests of the State are roughly the same in paternity actions and termination proceedings. The cost to the State would be vast. McNabb, 315 N.W.2d at 17. The imposition of such a financial burden is best left for legislative determination. See McNabb, separate opinion at 17-18.
The legislature might or might not wish to provide the services. Several states have adopted the uniform parentage act and provided counsel for indigent paternity defendants. Section 19(a) of that act provides that “the court shall appoint counsel for a party who is financially unable to obtain counsel.” See Hawaii Rev.Stat. § 584-19 (1976); Minn.Stat.Annot. § 257-69(1) (West Supp.1982); Mont.Code Ann. § 40-6-119 (1981); N.D.Cent.Code § 14-17-18 (1981); Wyo.Stat. § 14-2-116 (1977). While these states have adopted section 19(a) of the uniform parentage act it is significant that three other states in adopting the act have excluded section 19(a) as a part of their state law. See Cal.Civ.Code §§ 7000-7018 (West 1981); Colo.Rev.Stat. §§ 19-6 — 101 to 19-6-129 (1981); Wash.Rev.Code Ann. §§ 26-26.010 to 26.26.905; 74.20.350 (1981). In light of this divergent legislative opinion appointed counsel should not be judicially required.
IV. We next weigh whether the absence of counsel in a paternity action might result in erroneous determinations. In other words, would the presence of counsel make paternity proceeding determinations more reliable? The question in a paternity suit is really one of biology. In former times disputed claims of paternity were necessarily determined mainly from the examination and cross-examination of witnesses. Thanks to scientific developments the accuracy of blood tests has dramatically improved. We have noted that the accuracy of the tests is thought to approach mathematical certainty. See State ex rel. Buechler v. Vinsand, 318 N.W.2d 208, 210-11 (Iowa 1982). Indeed the accuracy of the tests is such that an indigent defendant has a due process right to blood tests at public expense. Little v. Streater, 452 U.S. 1, 14, 101 S.Ct. 2202, 2209, 68 L.Ed.2d 627, 637 (1981).
To accord a putative father a lawyer at public expense may be of some advantage in attempting to escape the test but it has less to do than it did in times past with improving the reliability of a paternity determination. The risk of error in a paternity action is not affected in an unusual degree by the presence or absence of counsel.
In any event the opportunity for an erroneous result in the absence of counsel is not categorically greater in paternity cases than in eases involving the termination of parental rights. Snodgrass’s federal due process claim for appointed counsel fails under the holding in Lassiter.
It is pointed out that a number of states have found a due process right to counsel in paternity action. See Reynolds v. Kimmons, 569 P.2d 799, 803 (Alaska 1977) (under state constitution); Artibee v. Cheboygan Circuit Judge, 397 Mich. 54, 59, 243 N.W.2d 248, 250 (1976) (under state constitution); Salas v. Cortez, 24 Cal.3d 22, 34, 154 Cal.Rptr. 529, 537, 593 P.2d 226, 234, cert. denied, 444 U.S. 900, 100 S.Ct. 209, 62 L.Ed.2d 136 (1979) (under both federal and state constitutions); Hepfel v. Bashaw, 279 N.W.2d 342, 348 (Minn.1979) (under supervisory power of court to ensure fairness); Wake Cty. ex rel. Carrington v. Townes, 53 N.C.App. 649, 654, 281 S.E.2d 765, 769 (1981), modified and remanded, 306 N.C. 333, -, 293 S.E.2d 95, 100-01 (1982) (under both federal and state constitutions); M. v. S., 169 N.J.Super. 209, 216, 404 A.2d 653, 656 (1979) (unspecified basis); Madeline G. v. David R., 95 Misc.2d 273, 276, 407 [744]*744N.Y.S.2d 414, 416 (1978) (under both federal and state constitutions); State ex rel. Graves v. Daugherty, 266 S.E.2d 142, 145-46 (W.Va.1980) (under state constitution). However, there are two reasons why this authority is less than compelling. First, most of these decisions are founded on interpretation of the local state constitution. Second, the decisions that found a federal due process right to counsel predate the Lassiter decision of the U.S. Supreme Court, and are seriously undermined by it.
There is contrary state authority. See Wake Cty. ex rel. Carrington v. Townes, 306 N.C. 333, -, 293 S.E.2d 95, 100 [slip opinion (N.C. July 13, 1982)] (no absolute due process right to appointed counsel in paternity cases; decision is vested in state trial court, subject to appeal); Sheppard v. Mack, 68 Ohio App.2d 95, 103, 427 N.E.2d 522, 528 (1980) (no due process or equal protection right to appointed counsel); State ex rel. Adult and Family Serv. Div. v. Stoutt, 57 Or.App. 303, 313, 644 P.2d 1132, 1137-38 (1982) (no due process right to appointed counsel under federal or state constitutions); State v. Walker, 87 Wash.2d 443, 445, 553 P.2d 1093, 1095 (1976) (no due process or equal protection right to appointed counsel).
No different result is mandated by our state constitution. In State v. Davis, 304 N.W.2d 432, 434 (Iowa 1981), we said:
The Supreme Court of Iowa is the final arbiter of the meaning of the Iowa Constitution, but when the federal and state constitutions contain similar provisions, they are usually deemed to be identical in scope, import, and purpose. [Authorities.] Special respect and deference is accorded United States Supreme Court interpretations of similar language in the federal constitution. [Authority.]
We reject Snodgrass’s due process challenge to the trial court’s refusal to appoint him counsel.
V. Snodgrass presents an alternative claim under the equal protection clause ' of both the federal and state constitutions. Our own equal protection clause (art. I § 6) places substantially the same limitations on state legislation as is placed by the equal protection clause of the Fourteenth Amendment to the federal constitution. City of Waterloo v. Selden, 251 N.W.2d 506, 509 (Iowa 1977).
The interests of the State are closely aligned with the relators who commence chapter 252A proceedings. But the interests of the State and the putative fathers are dissimilar. It is axiomatic that “[a]ll persons need not be treated alike to meet constitutional standards of equal protection. It is enough if all members of the same class are treated equally.” Hack v. Auger, 228 N.W.2d 42, 43 (Iowa 1975) (emphasis in original). “Equal protection assurances do not require dissimilar situations to be treated similarly.” Selden, 251 N.W.2d at 509. In providing counsel to the relators the State is aiding a class of plaintiffs whose interests closely resemble its own. Such exercise of a State’s right to promote its own interests through litigation does not carry with it.an obligation to support the litigation efforts of those opposing the State’s interests. The equal protection challenge is not well taken.
AFFIRMED.
All Justices concur except UHLEN-HOPP, J., REYNOLDSON, C.J., and McCORMICK and LARSON, JJ., who dissent.