Discretionary appointment of 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, Paternity - Defendant/Respondent
In State ex rel. Adult & Family Services Division v. Stoutt, 57 Or.App. 303 (Ct. App. 1982), the litigant attempted to establish a right to appointed counsel in a paternity case and raised both the state and federal constitutions. The Oregon Court of Appeals adopted the United States Supreme Court's approach in Lassiter and questioned whether the issues and procedures therein were such that "the presence of counsel . . . could not have made a determinative difference." The Oregon Court of Appeals explained that, while some paternity cases present complex questions of fact or law, the case-at-hand did not present such complexities and, as in Lassiter, an attorney would have had minimal effect on the outcome of the proceedings, resulting in no due process right to appointed counsel.
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: discretionary Qualified: yes