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).
Court Rule or Initiative, Termination of Parental Rights (Private) - Children
Tenn. Sup. Ct. Rule 13 Section (d)(2)(D) provides that for proceedings to terminate parental rights, “The court shall appoint a guardian ad litem for the child, unless the termination is uncontested. The child who is or may be the subject of proceedings to terminate parental rights shall not be required to request appointment of counsel.” Tenn. Sup. Ct. Rule 40A Section 1(c), which sets forth guidelines for guardians ad litem in contested adoptions, specifies that a guardian ad litem must be a licensed attorney.
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