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
Mo. Ann. Stat. § 211.211(1) states, "A child is entitled to be represented by ... a guardian ad litem in all proceedings under subdivision (1) [abuse/neglect proceedings] of subsection 1 of section 211.031." Mo. Ann. Stat. § 210.160 similarly specifies that “In every case involving an abused or neglected child which results in a judicial proceeding, the judge shall appoint a guardian ad litem to appear for and represent...[a] child who is the subject of [abuse and neglect] proceedings”, and a Supreme Court rule clarifies that “When appointing a guardian ad litem for a child, the court shall only appoint a lawyer licensed by the Supreme Court who has completed the training required by these standards.” Mo. Sup. Ct., Standards with Comments for Guardians Ad Litem in Missouri, Standard 1.0.
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