Right to counsel - prisoners
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).
In Payne v. Superior Court, 17 Cal. 3d 908 (1976), the Supreme Court of California vacated a default judgment against an inmate sued for civil money damages and unable to either obtain an attorney or appear personally to defend himself. Although the court made clear that not all indigents have a right to appointed counsel in civil cases, it found that if the state would not allow the incarcerated prisoner to appear personally in court, then counsel had to be appointed in order to protect the inmate's fundamental property interest. The Payne court made no suggestion that the right to counsel depended on the existence of a threat to physical liberty, but rather grounded its opinion on the due process right to access the courts. The court rendered its decision based on both the California and U.S. Constitutions.
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