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
Two appellate courts have held there is a right to counsel in stepparent adoption cases. See In re Jay, 197 Cal. Rptr. 672 (Cal. Ct. App. 1983) (indigent noncustodial parent accused of neglect has due process right to appointed counsel in stepparent adoption proceeding); Appellate Defenders, Inc. v. Cheri S. 42 Cal.Rptr.2d 195, 199(Cal. App. 1995) (finding indigent parent entitled to counsel where parent's custody/control rights have been terminated or consent found unnecessary in stepparent adoption proceeding, but not making clear whether right based on due process, equal protection, or statutory interpretation).
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