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, Sexually Dangerous Persons - Commitment
Fla. Stat. § 394.916(3) provides for appointment of the public defender or other counsel selected by the court in proceedings for involuntary civil commitment of sexually violent predators.
In Manning v. State, 913 So. 2d 37 (Fla. App. 2005), the Court of Appeals recognized a right to effective assistance of counsel in SVP proceedings, noting that a) the Supreme Court of Florida recognized such a right to effective assistance in civil commitments in Pullen v. State, 802 So. 2d 1113 (Fla. 2001); and b) in Williams v. State, 889 So. 2d 804, 806 (Fla. 2004), the Supreme Court of Florida had observed that "an involuntary civil commitment resulting in an individual's confinement for an indeterminate, and potentially indefinite, period of time presents the sort of 'massive curtailment of liberty interests' with which we were concerned in Pullen." Subsequent to Manning, “the Florida Supreme Court adopted rule 4.460, Florida Rules of Civil Procedure for Involuntary Commitment of Sexually Violent Predators. The rule provides that ineffectiveness of trial counsel may be asserted by filing a habeas corpus petition.” Bohner v. State, 157 So. 3d 526, 527 (Fla. App. 2015).
Cite: Fla. Stat. § 394.916(3)
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: no