Right to counsel - sterilization
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).
Vermont provides for the right to counsel for intellectually disabled adults prior to involuntary sterilization: "If the [sterilization] petition states that the respondent is unable to pay for counsel, the court shall appoint counsel to be paid by the state or set a hearing for a determination of respondent's ability to pay for counsel." 18 V.S.A. § 8710.
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