Discretionary appointment of 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
Mo. Ann. Stat. § 211.211 states that "[T]he court shall appoint counsel for the [child's] custodian if it finds . . . [t]hat the custodian is indigent[,] . . . desires the appointment of counsel[,] . . . [and t]hat a full and fair hearing requires appointment of counsel for the custodian."
In In re J.R., 347 S.W.3d 641, 645 (Mo. App. 2011), the court noted that "Several Missouri courts have taken the trial court's obligation a step further, and required that the trial court either appoint counsel for a parent or secure an affirmative waiver of counsel."
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: discretionary Qualified: no