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 Allen v. Sheriff of Lancaster County, 511 N.W.2d 125 (Neb. 1994), the court stated that it had decided in Carroll v. Moore, 423 N.W.2d 757, 766-67 (Neb. 1988) that "under the U.S. Constitution, an indigent litigant has a right to appointed counsel when, as a result of the litigation, he may be deprived of his physical liberty." Thus, the Allen court held there was a right to counsel in civil contempt proceedings. Because of the reliance on physical liberty and the 14th Amendment, this decision is under some question after the U.S. Supreme Court's decision in Turner v. Rogers.
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