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
Mont. Code Ann. § 41-3-425 provides that:
(2) Except as provided in subsections (3) and (4), the court shall immediately appoint the office of state public defender to assign counsel for:
(b) any child or youth involved in a proceeding under a petition filed pursuant to 41-3-422 when a guardian ad litem is not appointed for the child or youth; and
(c) any party entitled to counsel at public expense under the federal Indian Child Welfare Act.
(3) When appropriate, the court may appoint the office of state public defender to assign counsel for any child or youth involved in a proceeding under a petition filed pursuant to 41-3-422 when a guardian ad litem is appointed for the child or youth.
See also Mont. Code Ann. § 47–1–104(4)(b)(i) (specifying appointment of counsel regardless of indigence "as provided for in 41-3-425"). A public defender may be appointed on appeal as well. Mont. Code Ann. § 47–1–104(4)(c).
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