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).
Court Rule or Initiative, Guardianship/Conservatorship of Adults - Protected Person
In guardianship proceedings, Del. Code Ann. tit. 12 § 3901(c) specifies that the person with the alleged disability is only "entitled to representation by counsel," but there is no provision for appointment of counsel. However, Del. Ch. Ct. R. 176(a) (entitled "attorney ad litem") specifies that upon petition for appointment of a guardian, "the Court shall appoint a member of the Delaware Bar to represent the adult person alleged to be disabled if such person is not otherwise represented by counsel, to receive notice on behalf of such person and to give actual notice to such person, explain his or her rights, and the nature of the proceeding." While an "attorney ad litem" typically plays a best interests role, the rule goes on to state, "The attorney ad litem shall represent the person alleged to be disabled as if engaged by such person."
Del. Ch. Ct. R. 176(a) also states that "The Court, in its discretion, may appoint an attorney ad litem to represent a minor disabled person."
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