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).
Legislation, Civil Commitment - Subject of Petition
In proceedings regarding involuntary commitment of a mentally ill person, that person has a right to appointed counsel if indigent. Or. Rev. Stat. Ann. § 426.100(3)(b). The Oregon courts have clarified that under Or. Rev. Stat. § 426.100, the trial court does not have to advise an allegedly mentally ill person of his or her right to retain private counsel provided that the court has already made the determination that counsel had been appointed for the individual and he or she lacked the resources to retain private counsel. State v. J.C., 172 Or.App. 745, 749 (Ct. App. 2001). The judge is responsible for issuing a citation to the allegedly mentally ill individual, informing the person of their right to have legal counsel appointed if they cannot afford it. Or. Rev. Stat. Ann. § 426.090; see also Or. Admin. R. 309-033-0250(2) (whoever takes allegedly mentally individual into custody is responsible for informing of rights regarding appointment of counsel pursuant to Or. Rev. Stat § 426.100). If an individual decides to appeal a determination that he or she is mentally ill under Or. Rev. Stat. § 426.130, that individual has a right to counsel for the appeal if indigent. Or. Rev. Stat. Ann. § 426.135. See also Or. Rev. Stat. Ann. § 426.701(2)(c) (court must appointed counsel in proceedings to commit someone as “extremely dangerous’).
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