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 involuntary termination of parental rights proceedings. Ky. Rev. Stat. Ann. §§ 625.0405, 625.080(3).
In Commonwealth v. K.B.H., 2005 WL 2108126 at *3 (Ky. Ct. App. 2005), the court held that an attorney appointed at trial is obligated by the rules of ethics to handle the appeal, as a lawyer who agrees to represent a client is required to see the case through to completion, including "an appeal if so desired by the client." At the same time, the Kentucky Court of Appeals has held that counsel is not required to pursue a frivolous appeal, applying the standard from Anders v. State of California, 386 U.S. 738 (1967), to termination of parental rights cases). It also held that parents are not entitled to additional payment for appointed counsel at the appellate stage because Section 625.080 does not provide for it. The K.B.H. court conceded the $500 cap on attorney's fees did not keep pace with inflation and did not ensure meaningful access to an appeal, but held that "we cannot intrude upon the legislative prerogative and function to legislate."
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