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 Commitment - Subject of Petition
In State ex rel. Memmel v. Mundy, 249 N.W.2d 573, 576 (Wis. 1977), the court stated that “At least as to indigents involved in such proceedings, it is a constitutional requirement that legal representation be provided for the person whose commitment is sought”, and relied on similar rulings from federal courts. The fact that the Memmel court relied entirely on federal decisions makes it likely that this was a decision based on the Fourteenth Amendment, as opposed to the state constitution’s due process clause.
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