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 - Children
Mo. Ann. Stat. § 211.211 states:
The court shall appoint counsel for a child prior to the filing of a petition if a request is made therefor . . . and the court finds that the child is the subject of a juvenile court proceeding and that the child making the request is indigent . . . When a petition has been filed, the court shall appoint counsel for the child when necessary to assure a full and fair hearing. . . .
The Missouri Supreme Court incorporated substantially the same language into Rule 115, the statute's implementing rule. See Mo. R. RCP Rule 115.01 to .03. The statute is is difficult to parse, as it seems to suggest the child has a right to appointed counsel upon request prior to the filing of the petition, whereas post-petition the court must determine counsel is necessary for a full and fair hearing. On the other hand, Mo. Ann. Stat. § 210.160 specifies that "In every case involving an abused or neglected child which results in a judicial proceeding, the judge shall appoint a guardian ad litem to appear for and represent...[a] child who is the subject of [abuse and neglect] proceedings", and "When appointing a guardian ad litem for a child, the court shall only appoint a lawyer licensed by the Supreme Court who has completed the training required by these standards." Mo. Sup. Ct., Standards with Comments for Guardians Ad Litem in Missouri, Standard 1.0. Thus it appears that the court must appoint an attorney-GAL for all children, but may appoint separate counsel for the child in the court's discretion once a petition has been filed.
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