Right to counsel
Litigation, Termination of Parental Rights (Private) - Birth Parents
In In re Application to Adopt H.B.S.C., 12 P.3d 916, 920 (Kan. App. 2000), in finding a right to counsel for a putative father in an appeal of a stepparent adoption notwithstanding a lack of specific legislative language, the court observed:
There is no doubt that the relationship of natural parent and child is a fundamental right of which neither may be deprived without due process of law as guaranteed by the Constitution of the United States and the Kansas Bill of Rights. Nor can there be any doubt that, in such case, the right to counsel, either retained or appointed, is essential to due process.
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