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, Termination of Parental Rights (State) - Children
A lower court extended 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 right to counsel for parents in termination proceedings, and which was cited with approval for the New Jersey Constitution by the New Jersey Suprmee Court in Pasqua v. Council, 892 A.2d 663, 674 n.5 (N.J. 2006) and N.J. Div. of Youth & Family Servs. v. B.R., 929 A.2d 1034,1036 (N.J. 2007)) to provide a right to appointed counsel for children in dependency or termination proceedings. N.J. Div. of Youth & Family Servs. v. Wandell, 382 A.2d 711, 713 (N.J. Juv. & Dom. Rel. Ct. 1978) (finding right under both state and federal constitutions; "[s]urely if due process required that a mature adult subjected to these proceedings requires the assistance of able counsel, no less should be required to protect the interests of a minor incapable of speaking for himself.").
Wandell was subsequently cited with approval (albeit in a case where a child was appointed counsel pursuant to statute) in Matter of Adoption of a Child by E.T., 695 A.2d 734 (N.J. Super. Ct. App. Div. 1997).
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