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 (Private) - Birth Parents
Given that the Adoption Code is within Title 8, the right to counsel in § 8-221(B) should apply to adoption proceedings.
Additionally, in Frank P. v. Sabrina H., 2013 WL 5746220 (Ariz. App. 2013) (unpublished), the court held that in a case involving a petition by a private party for both termination of parental rights and adoption, the trial court appropriately appointed counsel for the petitioners in the termination portion, holding that "Nothing in A.R.S. § 8–221(B) limits [the right to counsel] to petitions brought by the Arizona Department of Economic Security." This unpublished opinion, however, cannot be cited as precedent in Arizona.
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