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 Enforcement (Civil Contempt)
In McNabb v. Osmundson, 315 N.W.2d 9, 13 (Iowa 1982), the Iowa Supreme Court held that the state was required to appoint counsel at public expense for an indigent defendant in a nonsupport civil contempt proceeding. The court analyzed federal due process requirements only, "mak[ing] no attempt to arrive at [its] own independent interpretation of the United States Constitution, but follow[ing] the federal decisions as [the court] under[stood] them." Because the defendant faced the prospect of incarceration, the court held that "[t]he potential sentence justifies our position that the nebulous distinctions between civil and criminal contempts are of no consequence in this jurisdiction." The court also held that the right to counsel extended to the appeal.
The court has not revisited its opinion since the U.S. Supreme Court's ruling 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