Right to counsel
While a state may have many statutes, court decisions, or court rules governing appointment of counsel for a particular subject area, a "Key Development" is a statute/decision/rule that prevails over the others (example: a state high court decision finding a categorical right to counsel in guardianships cases takes precedence over a statute saying appointment in guardianship cases is discretionary).
Litigation, Civil Commitment - Subject of Petition
A federal court held that in Michigan civil commitment cases, “the respondent has the right to legal counsel and, if indigent, to appointed counsel, to assist him at every step of the commitment proceedings; and further that he must be notified of this right at the outset of the proceedings. Bell v. Wayne Cty. Gen. Hosp. At Eloise, 384 F. Supp. 1085, 109 (E.D. Mich. 1974). The court relied on In re Gault, 387 U.S. 1 (1967) (finding right to counsel for juveniles in delinquency proceedings) as well as decisions from other federal courts.
If "yes", the established right to counsel or discretionary appointment of counsel is limited in some way, including any of: the only authority is a lower/intermediate court decision or a city council, not a high court or state legislature; there has been a subsequent case that has cast doubt; a statute is ambiguous; or the right or discretionary appointment is not for all types of individuals or proceedings within that category.
Appointment of Counsel: categorical Qualified: no