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).
Legislation, Civil Commitment
South Carolina imposes a mandatory counsel requirement for those who face involuntary hospitalization for mental illness. S.C. Stat. § 44-17-530 ("Within three days after [a] petition for judicial commitment [of a mentally ill person] is filed, ...the court shall appoint counsel to represent the person if counsel has not been retained."); see also S.C. Stat. § 44-24-90(D) (same for commitment of a child); S.C. Stat. § 44-24-60(F) (A court that finds probable cause for the involuntary admission of a child to a hospital for treatment because he is a danger to himself or others "shall appoint counsel for the child if he has not retained counsel...").
South Carolina has also adopted a right to counsel in broad measures that may require even a limited period of loss of liberty. S.C. Stat. § 44-52-60(E) (court that orders emergency drug or alcohol abuse detention "shall ... appoint counsel for the patient if counsel has not been retained..."); see also S.C. Stat. § 44-52-70 (guaranteeing a right to counsel for indigent individuals "at all stages of the [involuntary drug or alcohol commitment] proceeding"); S.C. Stat. § 44-52-80 (requiring court to provide subject of involuntary commitment proceeding with notice of right to counsel if indigent).
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