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).
Litigation, Termination of Parental Rights (Private) - Birth Parents
The Alaska Supreme Court held that indigent parents have a right to counsel under the Alaska Constitution whenever someone seeks to bypass their consent to adoption. The court found sufficient state involvement required to invoke due process.
Cite: Matter of K.L.J., 813 P.2d 276, 278 (Alaska 1991)
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