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
Indigent parents have a right to counsel in termination proceedings under the Adoption Act. 15A V.S.A. § 3-201(a).
Moreover, in an adoption relinquishment proceeding, "A parent who is a minor is competent to execute a consent or relinquishment if the parent has had the advice of an attorney who is not representing an adoptive parent or the agency to which the parent's child is relinquished. The attorney shall be present when the consent or relinquishment is executed." 15A V.S.A. § 2-405(c).
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