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, Bypass of Parental Input into Abortion - Minor
The Florida Supreme Court found a due process right to counsel in proceedings for a minor to bypass parental consent to abortion. In re T.W., 551 So. 2d 1186, 1196 (Fla. 1989). The court stated: "In [parental consent hearings] wherein a minor can be wholly deprived of authority to exercise her fundamental right to privacy [by obtaining an abortion], counsel is required under our state constitution." The court noted that the provision of counsel in In Interest of D.B., 385 So. 2d 83, 90-91 (Fla. 1980) (a prior case finding a right to counsel in termination of parental rights cases) was based on the fact that "an individual's interest in preserving the family unit and raising children is fundamental," and thus since "a woman's right to decide whether or not to continue her pregnancy constitutes a fundamental constitutional right," counsel is similarly required whenever one can be deprived of the authority to exercise that right. Despite relying upon a federal case, the In re T.W. court maintained that it was "expressly decid[ing] this case on state law grounds."
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