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, Paternity - Defendant/Respondent
In Salas v. Cortez, 593 P.2d 226 (Cal. 1979), the California Supreme Court held that due process under the state and federal constitutions requires appointment of counsel to represent indigent defendants in paternity proceedings in which the state appears as a party or appears on behalf of a mother or child.
The court noted that "[a]n adjudication of paternity may profoundly affect a person's life" since it might "disrupt an established family and damage reputations." Further, "a court's determination of paternity exposes a defendant to deprivation of property and, potentially, liberty" since failure to pay child support is enforceable by garnishment of wages and via criminal proceedings. Moreover, the Salas majority found that "[w]hile an indigent is entitled to counsel if prosecuted criminally for nonsupport, the most significant element of the offense paternity may have already been determined in a civil proceeding in which the defendant was unrepresented by counsel."
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