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 (State) - Birth Parents
Tenn. Code Ann. § 37-1-126(a)(2)(B)(ii) provides a right to counsel for "Termination of parental rights pursuant to § 36-1-113." While this provision refers to terminations conducted pursuant to the Adoption Code, in In re Carrington H., 483 S.W.3d 507, 527 (Tenn. 2016), the court in a state-initiated termination case cited to Tenn. Code Ann. § 37-1-126(a)(2)(B)(ii) for the proposition that “Tennessee statutorily provides the right to appointed counsel for indigent parents in every parental termination proceeding."
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