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, Child Support Enforcement (Civil Contempt)
The Alaska Supreme Court found a right to counsel for indigent defendants in civil contempt proceedings involving nonsupport. Otton v. Zaborac, 525 P.2d 537, 538 (Alaska 1974). It relied on the due process clauses of both the federal and state constitutions at the same time, and it is unclear whether there is an independent state constitutional ground that would surive the U.S. Supreme Court's negative ruling in Turner v. Rogers.
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