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).
Litigation, Custody Disputes - Children
In a set of cases, New Jersey courts have found that children in contested custody proceedings should be provided with independent counsel. Doe v. Div. of Youth & Family Servs., 398 A.2d 562 (N.J. Super. Ct. App. Div. 1979) (removal of child from foster parents and return to natural parents); Wilke v. Culp, 483 A.2d 420 (N.J. Super. Ct. App. Div. 1984) (visitation of natural father; child was "represented" by stepfather's counsel); Matter of Adoption of Mercado, 442 A.2d 1078 (N.J. Super. Ct. App. Div. 1982) (involuntary adoption). The courts in these cases did not state the basis for their holdings, although they appeared to fall under the same "fundamental fairness" test used in other cases.
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