Discretionary appointment of 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)
The Nevada Supreme Court has found a right to counsel in some contempt proceedings in family court "when the hearing may result in the imposition of a jail sentence for the nonpayment of child support." Rodriguez v. Eighth Judicial District Court, 102 P.3d 41, 43 (Nev. 2004).
The Rodriguez court reviewed the due process positions taken by other states in civil contempt proceedings with the possibility of a prison sentence, which either supported an absolute right to counsel for indigent parties, rejected any right to appointed counsel, or allowed for the discretionary appointment of counsel on a case-by-case basis. In the end, the Rodriguez court supported the discretionary model. Because a defendant does not risk imprisonment for civil contempt unless a trial court has determined that a defendant both has the ability to pay and is willfully refusing to pay, the Rodriguez court determined that the defendant's interest in personal freedom was not comparable to what was at stake in a criminal prosecution: "The real issue before the trial court is not the contemnor's ability to comply, but his unwillingness to do so." The government's interest was significant, and there was little risk for error because "the legal and factual issues in a nonsupport hearing are rarely complex." Notably, the litigant raised both the federal and state constitutions, and the court appeared to hold under both, commenting that "The language in Article 1, Section 8(5) of the Nevada Constitution mirrors the Due Process Clauses of the Fifth and Fourteenth Amendments to the United States Constitution ..."
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: discretionary Qualified: no