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, Incarceration for Fees/Fines (incomplete)
In Commonwealth v. Gomes, 552 N.E.2d 101 (Mass. 1990), a defendant was jailed without a hearing after failing to pay a court fine. After holding that he was entitled to a hearing, the high court relied on Argersinger v. Hamlin, 407 U.S. 25, 37 (1972) (right to counsel for misdemeanor felonies) for the proposition that [A]bsent a knowing and intelligent waiver, no person may be imprisoned for any offense, whether classified as petty, misdemeanor, or felony, unless he was represented by counsel at his trial."
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