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 Thomerson v. Thomerson, 387 N.W.2d 509 (S.D. 1986) (contempt for failure to pay alimony), abrogated on other grounds, Sazama v. State ex rel. Muilenberg, 729 N.W.2d 335 (S.D. 2007), the high court held that "[s]ince the punishment for civil contempt could be imprisonment, the accused is entitled to be represented by counsel as a matter of right." Given that the court relied on U.S. Supreme Court rulings (in particular, a criminal contempt case) and ALRs, the ruling was likely based on the federal constitution. Thomerson was later confirmed in Wold Family Farms, Inc. v. Heartland Organic Foods, Inc., 661 N.W.2d 719 (S.D. 2003), abrogated in part on other grounds, Sazama v. State ex rel. Muilenberg, 729 N.W.2d 335 (S.D. 2007). ("In the case of indirect contempt, civil or criminal, unless the trial judge predetermines the nature of the infraction is of insufficient gravity to warrant the imposition of imprisonment if the accused is found guilty, the unrepresented accused must be advised of his or her right to counsel ...If the accused is determined to be indigent, counsel must be appointed before any critical stage of the contempt proceeding").
These holdings are questionable after Turner v. Rogers, 131 S.Ct. 2507 (2011) (Sixth Amendment does not apply to civil contempt proceedings, and Fourteenth Amendment does not require categorical right to counsel in civil contempt, at least where opponent is neither the state nor represented and matter not "especially complex"), with respect to cases within Turner's bailiwick.
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