Discretionary appointment of 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 (Private) - Birth Parents
In 2018, the Kentucky Legislature in 2018 added KRS 199.502(3), which states:
Biological living parents have the right to legal representation in an adoption wherein he or she does not consent. The Circuit Court shall determine if a biological living parent is indigent and, therefore, entitled to counsel pursuant KRS Chapter 31. If the Circuit Court so finds, the Circuit Court shall inform the indigent parent; and, upon request, if it appears reasonably necessary in the interest of justice, the Circuit Court shall appoint an attorney to represent the biological living parent pursuant to KRS Chapter 31 to be provided or paid for (a) The petitioner a fee to be set by the court and not to exceed five hundred dollars ($500); or (b) The Finance and Administration Cabinet if the petitioner is a blood relative or fictive kin as established in subsection (4)(a) of Section 4 of this Act a fee to be set by the court and not to exceed five hundred dollars ($500).
However, in R.V. v. Com., Dept. for Health and Family Services, 242 S.W.3d 669 (Ky. App. 2007), the Court of Appeals held that "pursuant to both the due process clause of the Fourteenth Amendment to the United States Constitution and KRS 625.080(3) and 620.100(1),  the parental rights of a child may not be terminated unless that parent has been represented by counsel at every critical stage of the proceedings." The court did not confine its holding to state-initiated adoptions, so it arguably could be applied to the adoiption context notwithstanding the Legislature's discretionary language KRS 199.502(3).
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: yes