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, Guardianship/Conservatorship of Adults - Protected Person
Upon the filing of a guardianship petition, the court shall appoint an attorney for the allegedly incapacitated person unless the person is already represented by counsel. Ala. Code § 26-2A-102(b). The role of the attorney is that of a guardian ad litem. Id.
After guardianship has been granted, the protected person is entitled to an attorney in matters related to extension and termination of the guardianship: "Before appointing a successor guardian, or ordering that a ward's incapacity has terminated, the court shall follow the same procedures to safeguard the rights of the ward that apply to a petition for appointment of a guardian." Ala. Code § 26-2A-110(c).
As to an adult subject to a petition for conservatorship or other protective order, the law appears to require appointed counsel. While Ala. Code § 26-2A-135(d) states that such person is only “entitled to be represented by counsel, at the person's expense, § 26-2A-135(b) states, “Unless the person to be protected has chosen counsel, the court shall appoint an attorney to represent the person who may be granted the powers and duties of a guardian ad litem.”
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