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, Paternity - Defendant/Respondent
In Reynolds v. Kimmons, 569 P.2d 799, 803 (Alaska 1977), the Alaska Supreme Court held that an indigent defendant has a right to the appointment of counsel in a paternity suit in which the plaintiff is represented by the state. The Court based its decision on the due process clause of the Alaska Constitution. Id. at 801. In upholding the right to counsel, the Court noted that, “principles justifying appointment of counsel in criminal cases also apply to certain civil or quasi-civil proceedings.” Id. The Court observed that, for example, “a parent of a child under sixteen years of age who willfully fails to furnish support, without lawful excuse, may be held criminally liable and subject to a fine of not more than $500.00 or imprisonment for not more than twelve months or both.” Id. Due to the possibility of a loss of liberty, due process requires the appointment of counsel. Id. Additionally, the Court pointed out that paternity suits are brought by the state and “a determination of one of society's most important relationships, that of parent-child, is at stake.” Id. at 802. These are also important considerations that lead to the right to counsel in paternity cases. Id.
 The court noted that “The lawsuit was initiated by the Child Support Enforcement Agency, although the suit was brought in the name of the child's mother.” Id. at 802.
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: yes