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 Forfeiture
W. Va. Code, § 29-21-2 provides for appointment of public defenders in "forfeiture proceedings brought pursuant to article seven, chapter sixty-a of this code [§§ 60A-7-701 et seq.]." The referred-to article is the West Virginia Contraband Forfeiture Act.
The Supreme Court of Appeals of West Virginia has affirmed that proceedings listed in § 29-21-2 are "[t]he legal proceedings to which indigents are entitled to court appointed counsel …" Mooney v. Frazier, 693 S.E.2d 333, 337 (W. Va. 2010).
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