Discretionary appointment of 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, Abuse/Neglect/Dependency - Accused Parents
For dependency cases, the Public Defender Act ("PDA") states that counsel "shall be assigned" in "proceedings arising out of a petition brought in a juvenile court when the court deems the interests of justice require representation of either the child or his parents or guardian or both, including any subsequent proceedings arising from an order therein." 13 V.S.A. § 5232(3). See also 33 V.S.A. § 5306(d)(5) (in notice of temporary care hearing, there must be notice to "an attorney to represent the parent", and "[t]he attorney may be court-appointed in the event the parent is eligible").
Note that V.R.F.P. Rule 2 specifies that “[c]ounsel shall be assigned at the temporary care hearing or prior to the preliminary hearing …” (emphasis added). While this may be a reference to appointing counsel for all parents, it may simply mean that if counsel is to be assigned, it should be done at those times.
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: discretionary Qualified: no