Right to counsel
Litigation, Civil Commitment - Subject of Petition
In Heryford v. Parker, 396 F.2d 393, 396 (10th Cir. 1968), a federal appellate court relied on Application of Gault, 387 U.S. 1 (1967) to find a right to counsel in Wyoming civil commitment proceedings, and brushed aside the discretionary Wyoming appointment statute existing at the time as insufficient.
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