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, Bypass of Parental Input into Abortion - Minor
Mont. Code Ann. § 50-20-509 specifies that in proceedings for a minor to bypass parental consent for an abortion, " The youth court shall advise the minor of the right to assigned counsel and shall order the office of state public defender, provided for in 47-1-201, to assign counsel upon request." See also Mont. Code Ann. §§ 47–1–104(4)(b)(iv). A public defender may be appointed for indigent litigants on appeal as well. Mont. Code Ann. § 47–1–104(4)(c).
Note that a Montana court found that the notification requirement in section 50–20–212(2)(a) violates the Montana Constitution's Equal Protection Clause and privacy protection. Wicklund v. State, No. ADV-97-671 1998 Mont. Dist. LEXIS 227 (Mont. 1st Jud. Dist. Ct. Feb. 13, 1998) . H.B. 627 created a new notification requirement that was virtually identical to the original, and it was approved by the voters via referendum (LR-120) in November 2012. Subsequently, the legislature repealed the notice provision and replaced it with the consent provision. However, a district court in the First Judicial District found that Wicklund applies to the parental consent requirement, and so enjoined it. Planned Parenthood of Montana v. State of Montana, No. BDV-2013-407 (Mont. Dist. Ct. Jan. 31, 2014).
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