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, Abuse/Neglect/Dependency - Accused Parents
Florida guarantees counsel for indigent defendant parents at all stages of dependency cases. Fla. Stat. § 39.013(1), Fla. R. Juv. P. Rule 8.320.
See also Fla. Stat § 39.013(10) ("Court-appointed counsel representing indigent parents at shelter hearings shall be paid from state funds appropriated by general law."); Fla. Stat § 39.402(5)(b)(2) (during hearings to determine the placement of children in shelters, "if indigent, the parents have the right to be represented by appointed counsel"). However, if a parent voluntarily surrenders rights to a child, Florida statutory law does not provide a right to counsel in dependency proceedings. Fla. Stat. § 39.807 (2011)(d).
Fla. R Juv. P. 8.517 specifies that trial counsel cannot withdraw after a dependency or termination of parental rights order until determining whether the parent wants to appeal, and if so, until an order appointing appellate counsel has been entered.
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