Discretionary appointment of 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, Paternity - Defendant/Respondent
In Wake County v. Townes, 293 S.E.2d 95 (N.C. 1982), a paternity determination case, the North Carolina Supreme Court recognized that "a related threat of actual
imprisonment, based partially upon a prior determination of paternity, may arise in subsequent criminal or civil enforcement proceedings if such becomes necessary to secure a defendant- father's support obligation to his child," but held that such an uncertain "web of possibilities" was too removed and therefore did not trigger an automatic right to counsel. The court implied some cases not involving deprivation of liberty might nevertheless require the appointment of counsel, and that to determine whether such a defendant had a right to counsel, the trial court should evaluate "the vital interests at stake on both sides" and determine "the degree of actual complexity involved in the given case and the corresponding nature of defendant's peculiar problems, if any, in presenting his own defense without appointed legal assistance." Although the North Carolina Supreme Court in Townes denied a right to counsel, finding that there was "no absolute due process right to counsel in all civil paternity suits," the court seemed to leave the door open for case-by-case determinations in future proceedings where no liberty interest is at stake.
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: discretionary Qualified: no