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, Civil Contempt in Family Court
In In re Marriage of Stariha, 509 N.E.2d 1117 (Ind. Ct. App. 1987), the court found a Fourteenth Amendment right to counsel in cases involving contempt for failure to pay child support, due to the risk of incarceration.
It also found sufficient state action at play, despite the contempt having been filed by an individual:
It is difficult to imagine how the present case does not involve state action. Admittedly, Rebecca initiated this action as a private individual. However, the trial court found John in contempt for failure to pay child support pursuant to Rebecca's motion and sentenced him to thirty days. Certainly, John's incarceration, depriving him of his physical liberty for thirty days, amounted to state action. The court enforced a contempt proceeding that was initiated privately ... Here, there is a definite nexus between Rebecca's complaint for failure to pay child support and the trial court's finding of contempt and incarceration of John for the same activity.
While Stariha is an unpublished opinion and such opinions have no precedential value in Indiana, it has been subsequently relied upon by another court. In Moore v. Moore, 11 N.E.3d 980 (Ind. Ct. App. 2014), a case that came after Turner v. Rogers, 564 U.S. 431 (2011) (no right to appointed counsel under Fourteenth Amendment in civil contempt cases, at least where private party initiates contempt), the court, without mentioning Turner at all, relied on Stariha for the right to appointed counsel for child support contempt and Marks v. Tolliver, 839 N.E.2d 703, 706 (Ind. Ct. App. 2005) for the proposition that the right attaches even where a private person initiates the contempt.
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