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
In State v. Creamer, 528 So. 2d 667, 668-69 (La. Ct. App. 1988), the Second Circuit found a right to counsel in a case involving a civil petition for child support "because the judgment rendered against the defendant wherein he was uncounseled was used as a basis to punish him for contempt." The court relied on precedent from the Louisiana Supreme Court relating to criminal neglect where the court held that the right to counsel attaches in some predicate proceedings even where jail is not immediate possibility. The litigant in question had counsel for the actual contempt proceeding, although the authority for such was not cited.
Other appellate courts in Louisiana have disagreed with Creamer, but the high court has not weighed in.
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