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).
Legislation, Termination of Parental Rights (State) - Birth Parents
Minn. Stat. § 260C.163, subd. 3(b), which governs the hearing procedures for termination of parental rights cases, specifies that "Except in proceedings where the sole basis for the petition is habitual truancy, if the ... parent, guardian, or custodian desires counsel but is unable to employ it, the court shall appoint counsel to represent ... the parents or guardian in any case in which it feels that such an appointment is appropriate if the person would be financially unable to obtain counsel under the guidelines set forth in section 611.17." (emphasis added)
However, Minn. Stat. § 260C.176 subd. 3(7) provides that when a child is taken into detention, “the child and the child’s parent, guardian, or custodian have the right to be present and to be represented by counsel at the detention hearing, and  if they cannot afford counsel, counsel will be appointed at public expense for the child, or for any party, if it is a ... termination of parental rights matter.”
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