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 Establishment
In County of Los Angeles v. Superior Court, 162 Cal. Rptr. 636 (Ct. App. 1980), the county brought an action to establish an obligation, and the court cited to Salas v. Cortez, 593 P.2d 226 (Cal. 1979) (which found a state and federal constitutional right to counsel in paternity cases as a matter of due process) for the proposition that "the Supreme Court held that an indigent defendant in a paternity and child support action prosecuted by the district attorney is constitutionally entitled to appointment of free counsel to represent him. Accordingly, the county does not contest the appointment itself, but it contends that the court erred in ordering it to pay attorneys' fees ..."
Then, in County of Ventura v. Tillett, 183 Cal. Rptr. 741 (Ct. App. 1982), disapproved of on other grounds, County of Los Angeles v. Soto, 35 Cal.3d 483, 674 P.2d 750 (Cal. 1984), the court of appeals held that an indigent mother was entitled to counsel in proceedings involving a stipulated judgment to pay child support. The Tillett court relied on County of Los Angeles to broadly hold, "[a]n indigent defendant in a child support action prosecuted by the district attorney under Welfare and Institutions Code section 11350 is constitutionally entitled to appointment of free counsel to represent him."
Subsequent to County of Los Angeles and Tillett, several courts suggested that a child support matter must be connected to a paternity action in order to trigger a right to counsel. See e.g. County of Orange v. Dabbs, 35 Cal. Rptr. 2d 79 (Ct. App. 1994) (finding right to counsel for appeal of order requiring father to reimburse welfare benefits paid to mother, where order was connected to paternity proceeding).
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