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
Indigent parents have a right to counsel "Whenever the department or a licensed child placement agency is a party to child custody proceedings", and they must be informed of this right. M.G.L. ch. 119, § 29. Such hearings include proceedings in which a court is appointing a guardian for a minor. See M.G.L. ch. 119, § 29 (pointing to M.G.L. ch. 190B, §§ 5-201, 5-204 and 5-206).
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