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
In adoption proceedings, the petitioner must pay the reasonable legal fees of the birth parents. N.H. Rev. Stat. § 170-B:13(a). N.H. Stat. § 170-B:9 elaborates:
Any parent surrendering parental rights shall be represented by legal counsel who is not representing an intended adoptive parent or the agency, unless such representation is waived with approval of the court for good cause shown. This paragraph is not intended, however, to create a right to counsel to be provided by the state where the surrendering parent is indigent. Instead, this paragraph is intended to make clear that the petitioning party to the adoption shall provide the surrendering parent with legal counsel consistent with RSA 170-B:13 [the provision on reasonable fees], unless waived by the court for good cause shown.
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: no