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, Civil Contempt in Family Court
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.
categorical
yes
