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).
Legislation, Paternity - Defendant/Respondent
For parentage actions, Cal Fam Code § 7572(b) specifies that “The written materials for parents which shall be attached to the form specified in Section 7574 and provided to unmarried parents shall contain the following information: ... (3) An alleged father’s constitutional rights to... have an attorney represent him; and to have an attorney appointed to represent him if he cannot afford one in a paternity action filed by a local child support agency.” This is likely a statutory implementation of Salas v. Cortez, 593 P.2d 226 (Cal. 1979), which held that due process requires appointment of counsel to represent indigent defendants in paternity proceedings in which the state appears as a party or appears on behalf of a mother or child.
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