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
Minnesota provides a parent in adoption proceedings who is also a minor the “opportunity to consult with an attorney,” which shall be at the county’s expense if that parent is indigent. Minn. Stat. § 259.24, subd. 2 (2008).
Minn. Stat. § 259.52, subd. 12 provides a right to counsel for adoption-related parentage proceedings initiated by a putative father on an adoption registry.
Minn. R. Adopt. Proc. 23.07 provides a right to appointed counsel to parents or custodians of Indian children in any removal, placement, or termination proceedings related to adoption, and provides a discretionary appointment process for Indian children themselves.
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