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 McBride v. McBride, 431 S.E.2d 14 (N.C. 1993), the North Carolina Supreme Court held that appointment of counsel for indigent defendants was in fact required in a civil contempt case, if the case could result in a loss of liberty for the defendant.
The U.S. Supreme Court's ruling in Turner v. Rogers, 131 S.Ct. 2507 (2011) (Fourteenth Amendment does not require right to counsel in civil contempt, at least where opponent is neither the state nor represented and matter is not "especially complex") may have a negative impact on the McBride decision. The McBride court relied on a belief that there was a federal constitutional presumption in favor of counsel when physical liberty is threatened, but Turner put that idea to rest. And given that no independent state ground was provided, the McBride decision is on shaky ground, at least for cases within Turner's purview.
Subsequent to Turner, in Young v. Young, 736 S.E.2d 538 (N.C. App. 2012), the Court of Appeals cited both Turner and McBride but gave little indication of what it would do on civil contempt cases generally because it found that the defendant had failed to meet his burden of proving that he was indigent. The Young court did say, though, that "Contrary to Plaintiff's assertion, Turner does not stand for the proposition that counsel is not required only when the opposing party is also unrepresented; rather it finds both that in such a scenario, counsel is not required if there are appropriate safeguards in place, and that counsel is not 'automatically require[d]' in all civil contempt hearings for child support from indigent litigants.'"
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