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).
Litigation, Abuse/Neglect/Dependency - Accused Parents
In N.J. Div. of Youth & Family Servs. v. D.C., 571 A.2d 1295, 1299 (N.J. 1990), the New Jersey Supreme Court cited to Crist v. New Jersey Division of Youth & Family Services, 343 A.2d 815, 816 (N.J. Super. Ct. App. Div. 1975) (which found a constitutional due process right to counsel in termination of parental rights proceedings) for the proposition that "simple justice" requires appointment of counsel for proceedings giving temporary custody to the state via guardianship, as such proceedings "entail a cessation of visitation. That path leads to freeing the child for adoption." Such a holding would provide a constitutional right to counsel in abuse/neglect proceedings as well.
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