Right to counsel
Litigation, Civil Commitment
In Ex parte Ullmann, 616 S.W.2d 278, 283 (Tex. App. 1981), one court of appeals relied on decisions from federal courts to hold that "[t]he subject of an involuntary civil commitment proceeding has the right to effective assistance of counsel at all significant stages of the commitment process." See also Chrisman v. Chrisman, 296 S.W.3d 706, 707 (Tex. App. 2009) (stating that proceedings involving termination, involuntary civil commitment warrant the "effective assistance of counsel"); State for the Best Interest of Ortiz, 640 S.W.2d 67 (Tex. App. 1982) (citing to Ullmann in civil commitment case and stating that “appellant is entitled to representation by an attorney ad litem on appeal”, then ordering court to appoint appellate counsel).
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