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, Abuse/Neglect/Dependency - Accused Parents
Under the Illinois Juvenile Courts Act, which covers dependency and termination of parental rights, indigent “parents, guardian, legal custodian or responsible relative who are parties respondent” must be appointed counsel if indigent. 705 Ill. Comp. Stat. Ann. 405/1-5(1). See also In re Adoption of L.T.M., 824 N.E.2d 221, 230 (Ill. 2005). The statute further specifies that "Counsel appointed for the minor and any indigent party shall appear at all stages of the trial court proceeding..."
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