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).
Ohio Rev. Code Ann. § 5123.86 provides that the sterilization of a person in mental health facility is not allowed without informed consent, but if a protected person is not capable of consent, the guardian can do so. If there is no guardian, the court can approve the recommendation of the chief medical officer of the facility, but the protected person has the right to appointed counsel if indigent to “contest the recommendation of the chief medical officer.”
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: yes