Right to counsel
Litigation, Civil Commitment - Subject of Petition
In Tetro v. Tetro, 544 P.2d 17, 19 (Wash. 1975), the Washington Supreme Court stated that "In proceedings civil in form but criminal in nature -- such as ... mental commitment hearings -- representation is clearly part of due process," and cited to Heryford v. Parker, 396 F.2d 393 (10th Cir. 1968) and Lessard v. Schmidt, 349 F. Supp. 1078 (E.D. Wis. 1972). But as Tetro did not involve civil commitment, its statement was dicta.
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