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) - Children
As per M.G.L. ch. 119, § 29(5), children have a right to appointed counsel in court determinations of the future status of children committed to the responsibility of the Department, including permanency plan hearings under chapter 119, § 29B.
Additionally, children shall be entitled to the appointment of counsel in proceedings initiated by the Department of Children and Families or a licensed child care agency, independent of a petition for adoption, "to dispense with the need for consent of any person to the adoption of the child in the care or custody of the department or agency" unless the petition is not contested by any party. M.G.L. ch. 210, § 3(b).
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