Right to counsel
Litigation, Termination of Parental Rights (State) - Birth Parents
Some appellate courts have said that there is a due process right to counsel in parental rights severance proceedings. See e.g. Daniel Y. v. Ariz. Dept. of Econ. Sec., 77 P.3d 55, 58 (Ariz. Ct. App. 2003); Christy A. v. Ariz. Dept. of Econ. Sec., 173 P.3d 463, 471 (Ariz. Ct. App. 2007); Denise H. v. Ariz. Dept. of Econ. Sec., 972 P.2d 241, 243 (Ariz. Ct. App. 1998); In re Pima County Juvenile Action J-64016, 619 P.2d 1073, 1075 (Ariz. Ct. App. 1980).
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