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).
Legislation, Termination of Parental Rights (State) - Children
For termination of parental rights proceedings, KRS § 625.080(2) states that “a guardian ad litem shall be appointed to represent the best interests of the child,” but no makes no mention of “counsel.” However, the Supreme Court of Kentucky has interpreted guardian ad litem to mean counsel:
This statute does not refer to the attorney appointed to represent the child as a guardian ad litem. In termination actions, however, both voluntary, KRS § 625.041, and involuntary, KRS § 625.080, a “guardian ad litem” must be appointed “to represent the best interests of the child.” The GAL's fee is likewise limited to $500 and is paid, if the Cabinet of Health and Family Services is the proposed custodian, by the Finance and Administration Cabinet. The different terminology does not appear to reflect a substantive distinction, and indeed CR 17.03(5), addressing GAL reimbursement, expressly provides that “fees allowed to counsel for children ... in dependency, abuse or neglect cases ... shall not exceed the amounts specified in KRS § 620.100.” In any event, it is clear that in practice the attorney appointed to represent the child in a DNA action, or, as in this case, in a domestic custody proceeding, is commonly thought of and referred to as a “guardian ad litem.”
Morgan v. Getter, 441 S.W.3d 94, 109 n.6 (2014).
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: no