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, Child Support Establishment
Extending the Connecticut Supreme Court's decision in Lavertue v. Niman, 493 A.2d 213 (Conn. 1985) (finding due process right to counsel in paternity cases under the state and federal constitutions), a court in Wood v. Walker, 2004 WL 1664229 (Conn. Super. Ct. June 25, 2004) (unpublished), held that the right to counsel in an underlying paternity action continued after paternity was established, i.e., to the subsequent child support determination. The court brushed aside the state's argument that the right to counsel only applied to "putative" fathers, relying instead on the general language in Lavertue and the fact that a parent subject to a child-support order could be subject to criminal prosecution for failure to comply with that order.
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