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, Guardianship/Conservatorship of Adults - Ward
N.Y. Mental Hyg. Law §§ 81.10, 81.11(e) requires appointment of counsel in guardianship proceedings where requested, where a petition is contested, where the court thinks it would be helpful, where "the court is not satisfied that the person is capable of making an informed decision regarding the appointment of counsel", or some other scenarios specified in the statute. See In re Turner, 730 N.Y.S.2d 188, 190 (App. Div. 2001) ("[I]ndigent defendants in the Criminal and Family Courts, and poor [allegedly incapacitated persons] and [incapacitated persons] in Article 81 proceedings have the right to appointment of effective counsel.").
Turner also suggested that counsel is provided when the guardianship is being modified. See also In Re Diurno, 182 Misc. 2d 205 (NY.Sup.Ct. 1999) (procedural safeguards for guardianship on review are "essentially the same").
Note that N.Y. Mental Hyg. Law §§ 81.10 and 81.11(e) do not apply to guardianships conducted under Article 17-A of the Surrogate's Court Procedure Act (which applies only to persons with a diagnosis of a developmental or intellectual disability).
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