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) - Birth Parents
See Ind. Code §§ 31-35-1-12(7) (right to appointed counsel "throughout any proceedings to terminate the parent-child relationship against the will of the parents"), 31-32-4-1 ("[t]he following persons are entitled to be represented by counsel: . . . (2) [a] parent, in a proceeding to terminate the parent-child relationship ..."), 31-32-4-3 ("If: (1) a parent in proceedings to terminate the parent-child relationship does not have an attorney who may represent the parent without a conflict of interest; and (2) the parent has not lawfully waived the parent's right to counsel ... the juvenile court shall appoint counsel for the parent at the initial hearing or at any earlier time.")
The Indiana Supreme Court ruled in September 2010 that the right extends to appeals as a matter of statutory construction, reversing the Indiana Court of Appeals on that point. In re I.B., 933 N.E.2d 1264 (Ind. 2010).
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