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) - Birth Parents
R.I. Stat § 15-7-5 provides various adoption scenarios in which the consent of the parents is not required (usually where the parent is not the custodian of the child at the time of the petition for adoption), but no right to counsel is provided. There is a right to counsel for abuse/neglect proceedings, R.I. Stat § 40-11-7.1, but it is not applicable to the separate adoption proceedings. However, RI Gen. Laws 14-1-31 (entitled “Proceedings in family court” within the “Delinquent and Dependent Children” chapter) states, “Prior to the commencement of any hearing, the justice shall advise the parent … that if he or she is financially unable to engage counsel, he or she is entitled to the services of the public defender.” This provision is not self-limiting to Title 14 proceedings, so it is possible it applies to Title 15 proceedings as well. Additionally, R. Juv. P., Rule 18 provides for appointment of counsel in contested termination of parental rights proceedings, and it appears it applies to the adoption statute since adoptions are the way that even the state terminates parental rights.
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