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
Indigent parents have a right to counsel upon request in termination of parental rights cases. Iowa Code § 232.113(1).
In In re E.J.C., 731 N.W.2d 402, 404 (Iowa Ct. App. 2007), the court held that the statutory right to counsel cannot be denied to an indigent parent facing involuntary termination proceedings, even where the request for counsel is made on the eve of the hearing.
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