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 Denton v. Commonwealth, 383 S.W.2d 681, 682 (Ky. 1964), a case involving the predecessor statutes for involuntary mental illness hospitalizations, the Court of Appeals (which was the state high court at the time) held that, because such “a proceeding may lead to the loss of personal liberty, the defendant in that proceeding should be afforded the same constitutional protection as is given to the accused in a criminal prosecution.” The court referenced the Sixth Amendment to the U.S. Constitution and a comparable provision in the Kentucky Constitution, but the court only discussed the right of confrontation supplied by those provisions, and specifically held that “the burden of proof . . . and the manner of proceeding and the rules of evidence should be the same as those in any criminal or quasi criminal proceeding.” Earlier, in the opinion’s factual recitation, the court did note that counsel had been appointed for the defendant.
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