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 In re Hop, 623 P.2d 282 (Cal. 1981), the California Supreme Court held that in the civil commitment of a developmentally disabled minor, such person is "entitled to the appointment of counsel" because "(i)nasmuch as a minor (or a developmentally disabled adult) may be presumed to lack the ability to marshal the facts and evidence, to effectively speak for himself and to call and examine witnesses, or to discover and propose alternative treatment programs, due process also requires that counsel be provided ....'" The court's holding appears to apply to all respondents, not just minors.
Additionally, in Petition of Antoine C., 186 Cal. App. 3d 424, 230 Cal. Rptr. 738, 740 (1986), the court considered the county's contention that the word “counsel” could be construed to mean a nonlawyer advisor rather than an attorney. The court held that the provision of a nonlawyer advisor rather than a lawyer violated Roger S., because “if the California Supreme Court intended ‘counsel’ to mean something other than ‘attorney’ it would have said so.”
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