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
There is a right to counsel for the indigent subject of a civil commitment proceeding. 18 V.S.A. § 7111. According to the statute, this right extends to "any proceeding before, or notice to, a court of this state involving a patient [qualified for treatment as a mentally ill or mentally retarded individual]." See also 18 V.S.A. §§ 7613 (stating court shall appoint counsel upon filing of application), 7621 (incorporating § 7613 for continued treatment proceedings), 7625 (incorporating § 7613 for involuntary medication).
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