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 Commitment - Subject of Petition
in Rashid v. J.B., 410 N.W.2d 530 (N.D. 1987), the court held that indigent litigants in civil commitment proceedings were entitled to counsel. Recognizing the commitment as a "massive curtailment of liberty" (a cite to Vitek v. Jones, 445 U.S. 480, 491 (1980)), the court noted that "the constitutional safeguards afforded criminal defendants are generally extended to those involved in civil commitment proceedings ... One such procedural safeguard provided in mental health proceedings is the right to counsel." The court then found that the statutory right to counsel had been created "[i]n accord with the fourteenth amendment of the federal Constitution ..."
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: no