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 State v. Stone, 268 P.3d 226, 235 (Wash. Ct. App. 2012), a Court of Appeals held that due process requires appointment of counsel in enforcement proceedings for legal financial obligations (LFOs) stemming from criminal convictions if incarceration is an immediate possibility.
After determining that the LFO proceedings were "criminal in nature", the Stone court extended the ruling in Tetro v. Tetro, 544 P.2d 17, 19 (Wash. 1975) (right to counsel in civil contempt cases) to the instant situation. It also distinguished the U.S. Supreme Court's decision in Turner v. Rogers because the LFO defendants faced a state prosecutor, not an unrepresented private party. Additionally, it pointed out that the Department of Corrections had terminated its supervision of the defendant, and so his liberty interest was not conditional as with the probation revocation or parole situations (like Gagnon v. Scarpelli, where the right to counsel is on a case-by-case basis). The court concluded that "regardless of whether we label the LFO enforcement proceedings as civil or criminal, Stone had a due process right to appointed counsel at public expense that was abrogated by the trial court proceedings." Id. at 235.
See also Smith v. Whatcom County Dist. Court, 52 P.3d 485, 487 (Wash. 2002) (person jailed for failure to pay fines; court applies Tetro).
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: no