Right to counsel
Litigation, Abuse/Neglect/Dependency - Accused Parents
A federal court found a federal due process right to counsel for indigent parents in Alabama dependency proceedings. Roe v. Conn, 417 F.Supp. 769, 780 (M. D. Ala. 1976). But the case precedes the U.S. Supreme Court's decision in Lassiter v. Dept of Soc Servs (which was about termination, not dependency), so it is possible it is no longer good law.
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