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 (State) - Children
Conn. Gen. Stat. Ann. § 45a- 717(b) specifies that "[u]nless the appointment of counsel is required under section 46b-136, the court may appoint counsel to represent or appear on behalf of any child in a hearing held under this section to speak on behalf of the best interests of the child." Appointment of counsel should be required under Section 46b-136 for all children in termination proceedings (since a termination proceeding is a proceeding "in which the custody of a child is at issue"), and additionally the appellate court's ruling in In re Christina M, 877 A.2d 941, 949-50 (Conn. App. 2005), extended the statutory right to counsel for children in § 46b-129a(2)(A) to termination proceedings.
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