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 (Private) - Birth Parents
A court must appoint counsel in adoption proceedings to represent any father whose identity or whereabouts are unknown, Kan. Stat. Ann. § 59-2136(c), and any indigent father (or mother) who appears and asserts parental rights, Kan. Stat. Ann. § 59-2136(h). While § 59-2136 refers to "father", it applies to mothers too because § 59-2136(b) states, "Insofar as practicable, the provisions of this section applicable to the father also shall apply to the mother …"
This right to counsel continues through the appeal. In re Application to Adopt H.B.S.C., 12 P.3d 916, 921-922 (Kan. Ct. App. 2000).
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