Right to counsel

An indigent parent has the right to counsel in contested adoption cases, except if the parent has not visited nor seen the child for 6 months. Va. Code Ann. § 63.2-1203(C).

Also, if a birth parent is entitled to a hearing, e.g., where a putative birth father objects to the adoption after having received notice of the matter, "[t]he juvenile and domestic relations district court may appoint counsel for the birth parent(s)." Va. Stat. § 63.2-1233(2).  Furthermore, the section provides:

If a child has been under the physical care and custody of the prospective adoptive parents and if both birth parents have failed, without good cause, to appear at a hearing to execute consent under this section for which they were given proper notice pursuant to § 16.1-264, the juvenile and domestic relations district court may grant the petition without the consent of either birth parent and enter an order waiving consent and transferring custody of the child to the prospective adoptive parents. Prior to the entry of such an order, the juvenile and domestic relations district court may appoint legal counsel for the birth parents...

Va. Stat. § 63.2-1233(4) (emphasis added).