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) - Children
In any proceeding to have a minor child declared free from the custody and control of either or both parents (which is one of the two possible avenues for adoption, and which can be invoked by private parties as per Cal. Fam. Code § 7841), the court “shall” appoint counsel to represent a dependent child unless it finds no benefit in doing so. Cal. Welf. & Inst. Code § 366.26(f)(1).
A minor child in such a proceeding who has not previously been adjudicated as dependent will be appointed counsel only at the discretion of the court. Cal. Fam. Code § 7861 (“The court shall consider whether the interests of the child require the appointment of counsel. If the court finds that the interests of the child require representation by counsel, the court shall appoint counsel to represent the child, whether or not the child is able to afford counsel.”)
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