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, Guardianship/Conservatorship of Adults - Protected Person
In re St. Luke's-Roosevelt Hosp. Ctr., 607 N.Y.S.2d 574, 580 (Sup. Ct. 1993), aff’d, 89 N.Y.2d 889 (N.Y. 1996), the court held that
[A]t least where an Article 81 petition seeks powers for a guardian of the person to either place the [allegedly impaired person] in a nursing home or other institutional facility, or to make major medical decisions, an indigent [allegedly impaired person] is constitutionally entitled to the appointment of counsel at state expense.
The court found that the privacy interests and risks of erroneous deprivation were high—because involuntary nursing home placement is dangerous to the person's health and because it implicates the person's liberty interests—while the state's interests (primarily the cost of providing the guardian) were low. The Court found that a forced relocation to a nursing home implicated a fundamental right akin to physical liberty.
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