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 found a right to counsel for indigent defendants in paternity proceedings under the Alaska Constitution's due process clause where the plaintiff is represented by the state. The court relied on the quasi-civil nature of the proceedings, the potential criminal charges stemming from future nonsuppoort, and the importance of the establishment of the parent-child relationship.
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