Personally I wouldn't use target fixation in a conversation about counter steering. They are not directly related.
On a woods/mx bike a lot of counter steering only occurs when you are correcting for rear wheel lateral slip. A lot of woods/mx turning occurs with very little leaning. On a bike with woods/mx/trials geometry you can ride fairly fast before the transition to counter steering occurs. I wouldn't consider counter steering in the middle of a 35 mph berm. What little experience I have on a trials bike tells me you would never counter steer unless you riding on the road at speed.
A bike with street only geometry requires counter steering at anything over a pushing speed. I am amazed at how many life long street riders tell me I'm crazy when I tell them that they are turing the front wheel left to go right.
I don't think I ever actually decide to steer or counter steer when I am riding or racing. I react from experience (prior pain).