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 Contempt in Family Court
In Brooks v. United States, 686 A.2d 214 (D.C. 1996), the court held that contemnors could not be incarcerated without first being appointed counsel, even in summary contempt situations. The court relied on a host of decisions from federal and state courts, as well as the Supreme Court's decision in Argersinger v. Hamlin, 407 U.S. 25 (1972), holding that "[a]pplying the Argersinger principle to civil and nonsummary criminal contempt reflects a recognition that 'any deprivation of liberty is a serious matter.'" 686 A.2d at 23. This decision is questionable after the U.S. Supreme Court's decision in Turner v. Rogers.
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