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, Custody Disputes - Children
in Balboni v. Balboni, 654 N.E.2d 937, 938 (Mass. Ct. App. 1995), the court held that in a divorce proceeding, a child must be appointed counsel pursuant to M.G.L. ch. 119, § 29 if the child is not able to retain counsel when involvement of the Department of Social Services becomes imminent and the judge is considering awarding custody of the children to the Department of Social Services.
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: yes