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, Guardianship/Conservatorship of Adults - Protected Person
In Guardianship of Zaltman, 843 N.E.2d 663 (Mass. App. 2006), the Massachusetts Court of Appeals held that where a ward seeks to remove the guardian and wants to retain counsel for the purpose, the court has to evaluate whether the ward is capable of retaining counsel, and if not, the court must appoint counsel.
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