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 Johnson v. Johnson, 721 P.2d 290 (Kan. Ct. App. 1986), the court of appeals reversed the order incarcerating a civil contemnor who had not been appointed counsel in a case involving the failure to pay child support. The court's reversal was entirely based on the Tenth Circuit's ruling in Walker v. McLain, 768 F.2d 1181 (10th Cir.1985), finding that "due process does require, at a minimum, that an indigent defendant threatened with incarceration for civil contempt for nonsupport, who can establish indigency under the normal standards for appointment of counsel in a criminal case, be appointed counsel to assist him in his defense." Thus, its ruling appeared to be based entirely on the federal constitution. Because of this, this case would likely be limited by 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