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).
NOTE: this is a very complex area of law, especially as it relates to stay-at-home orders issued by the states. Please read our primer on quarantine/isolation law before reading this specific state law.
One New York court ruled that indigent persons have a due process right to have counsel assigned in an involuntary hospitalization proceeding for disease since their liberty is in jeopardy. Rapoport v. G.M., 657 N.Y.S.2d 748, 748-49 (App. Div. 1997) (addressing rights for involuntary hospitalization under N.Y. Pub. Health Law § 2120 for communicable disease). The court cited to both Lassiter and to Rivers v. Katz, 495 N.E.2d 337 (N.Y. 1986). As a decision of only one of the intermediate courts of NY, it would not be precedent for the entire state.
Outside of the context of commitment to the state's custody for communicable disease, NY CLS Pub Health § 2100(2) provides that "Every local board of health and every health officer may: (a) provide for care and isolation of cases of communicable disease in a hospital or elsewhere when necessary for protection of the public health..." It is unclear whether Rapoport would cover a scenario where an individual is quarantined or isolated to a place other than a state hospital (such as their home).
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