Discretionary appointment of 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).
Litigation, Termination of Parental Rights (Private) - Birth Parents
In Walker v. Walker, 892 A.2d 1053, 1055 (Del. 2006), the Delaware Supreme Court stated that its reasoning from Watson v. Division of Family Services, 813 A. 2d 1101, 1108 (Del. 2002) and Hughes v. Div. of Family Services, 836 A.2d 498, 509 (Del. 2003), which held that the constitutional right to counsel in state-initiated termination and dependency cases is on a case-by-case basis, applies to private termination proceedings.
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: discretionary Qualified: no