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
Children have a right to the appointment of a guardian ad litem who is an attorney in termination proceedings. D.C. Code § 16-2304(b)(5). The GAL's role is to represent the child's best interests. Because the role of the GAL is best interests and not client-directed, the right to counsel is listed as "qualified."
But under SCR Neglect and Abuse Rule 42, the court has the ability to appoint a separate attorney as well. SCR Neglect and Abuse Rule 42 ("An attorney shall be appointed to serve as guardian ad litem for a child or children alleged to be neglected and the Court may, in addition, appoint an attorney to represent such child or children.").
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