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 Johnson v. Nelms, 100 S.W.2d 648, 652 (Tenn. 1937), the court held that for an insanity commitment hearing, "It is the duty of the trial court to see that the rights of the party whose sanity is questioned are fully guarded and protected; that in the absence of counsel, a competent and disinterested member of the bar is appointed to represent him . . . ."
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