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).
Legislation, Guardianship/Conservatorship of Adults - Ward
Cal. Health & Safety Code § 416.95 requires appointment of counsel for an adult developmentally disabled person from whom guardianship or conservatorship is sought.
For other guardianships, Cal. Prob. Code § 1471(a) requires appointment of counsel only upon request for those "unable to retain legal counsel". If not requested, appointment is discretionary with the judge and appropriate where "appointment would be helpful to the resolution of the matter or is necessary to protect the [person's] interests." Cal. Prob. Code § 1470.
See also Cal. Welf. & Inst. Code §§ 5350.5 (if court refers conservatee for assessment “to determine if the conservatee has a treatable mental illness, including whether the conservatee is gravely disabled as a result of a mental disorder or impairment by chronic alcoholism, and is unwilling to accept, or is incapable of accepting, treatment voluntarily”, then court must appoint counsel for conservatee if indigent); 5365 (for conservatorships of gravely disabled persons, “A hearing shall be held on all petitions under this chapter within 30 days of the date of the petition. The court shall appoint the public defender or other attorney for the conservatee or proposed conservatee within five days after the date of the petition.”)
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