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
Cal. Fam. Code § 7861 provides, "The court shall consider whether the interests of the child require the appointment of counsel. If the court finds that the interests of the child require representation by counsel, the court shall appoint counsel to represent the child, whether or not the child is able to afford counsel." However, in a proceeding specifically to terminate parental rights to a dependent child, the court "shall" appoint counsel to represent the minor child unless it finds no benefit in doing so. Cal. Welf. & Inst. Code § 366.26(f)(1).
In In re Richard E., 146 Cal. Rptr. 604, 607 (1978), superseded by statute, Cal. Civ. Code § 237.5 (current version at Cal. Fam. Code §§ 7861), the California Supreme Court found that it would be an abuse of discretion to not consider whether to appoint counsel for the child and to not appoint counsel where "the court finds a child has separate interests not protected in the contest between parents and a petitioner . . . . counsel is  required in the absence of an affirmative showing the minor's interests would otherwise be protected."
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