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, Termination of Parental Rights (Private) - Birth Parents
Under Mo. Ann. Stat. § 453.030(11), "A birth parent, including a birth parent less than eighteen years of age, shall have the right to legal representation and payment of any reasonable legal fees incurred throughout the adoption process." The statute adds, "in addition, the court may appoint an attorney to represent a birth parent" if certain conditions are met. These appointment conditions are slightly less onerous than § 211.211, requiring only that the birth parent request such counsel, not already be represented by counsel, and be, in the court's view, faced with "financial hardship" if obliged to hire an attorney out of pocket. The import of the overlapping provisions appears to be that a birth parent can either hire an attorney and submit for reimbursement of "reasonable" fees (presumably at the end of the proceedings) as a matter of right, or attempt to secure appointed counsel (subject to the discretion of the court) and thus avoid the reimbursement issue.
Section 453.030(12) adds that under ordinary circumstances, the attorney's fees of the private or appointed attorney are paid by either "the prospective adoptive parents or the child-placing agency" (the statute does not say how the court is to choose). If, however, the court opts to have the adoptive parents pay and they are financially unable to do so, then apparently the court's course of action under § 453.030(12) is to "appoint pro bono counsel for the birth parents," seemingly allowing conscription of an attorney without payment.
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