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).
Litigation, Termination of Parental Rights (State) - Birth Parents
In K.P.B. v. D.C.A., 685 So.2d 750 (Ala. Civ. App. 1996), the court held that the Alabama Supreme Court decision in Ex parte Shuttleworth, 410 So. 2d 896, 897 (Ala. 1981) (which found a due process right to counsel in termination of parental rights cases) was based on the Alabama Constitution, and so survived the U.S. Supreme Court's holding in Lassiter v. Dep't of Soc. Servs., 452 U.S. 18 (1981).
Cite: Ex parte Shuttleworth, 410 So. 2d 896, 897 (Ala. 1981)
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