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)
An intermediate court found a due process right to counsel for indigent litigants in civil contempt proceedings. It relied entirely on the threat to physical liberty, and did not clarify whether it was interpreting the state or federal constitution. It is uncertain whether it is still good law after the U.S. Supreme Court's decision in Turner v. Rogers.
Cite: Padilla v. Padilla, 645 P.2d 1327, 1328 (Colo. Ct. App. 1982)
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