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 both voluntary and involuntary termination of parental rights proceedings, the court must appoint a guardian ad litem for any child who is the subject of a contested adoption proceeding. Wis. Stat. § 48.235(1)(c). However, “[i]f the guardian ad litem determines that the best interests of the [child] are substantially inconsistent with the wishes of that [child], the guardian ad litem shall so inform the court and the court may appoint counsel to represent that [child].” Wis. Stat. § 48.235(3).
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