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).
03/08/2023, Legislation, Termination of Parental Rights (Private) - Children
If an adoption is contested, the court must appoint a guardian ad litem (GAL) for the adoptee. Ala. Stat. § 26-10A-22(b). The appointment may occur before or after the filing of the adoption petition. Although the Adoption Code does not define "guardian ad litem," the title of the section is "Attorney participation and appointment of attorney for the adoptee or other party," so it seems that a GAL must be an attorney. Additionally, the Comment to this section of the code specifies, “In a contested adoption, appointment of an independent attorney is mandated to ensure the best interest of the minor is protected.”
For adoptees where the adoption is uncontested, the court may appoint a GAL for the adoptee upon the motion of any party or upon the court's own motion. Id.
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