Right to counsel
Litigation, Civil Commitment
An appellate court held in State v. Collman, 9 Or.App. 476, 483 (Ct. App. 1972), that Fourteenth Amendment due process required appointed counsel prior to any mental health commitment. The court relied on the U.S. Supreme Court's decision in In Re Gault, 387 U.S. 1 (1967), as well as a number of federal court decisions and the fact that "involuntary incarceration" was at stake.
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