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
There is a right to counsel for an indigent "parent of a child in any adoption proceeding who opposes the adoption of such child." N.Y. Fam. Ct. Act § 262(a)(vii); N.Y. Surr. Ct. Proc. Act § 407(1)(a)(iii); see also N.Y. Soc. Serv. Law § 384-b(3)(e) (requiring notice to parents "of their right to the assistance of counsel, including any right they may have to have counsel assigned by the court in any case where they are financially unable to obtain counsel" in a proceeding to free a destitute or dependant child for adoption).
This right to counsel extends to the appeal. N.Y. Fam. Ct. Act § 1120(a).
Where these proceedings take place in the New York Supreme Court, the parties have the same rights to counsel as identified above. N.Y. Jud. Law § 35(8) (providing for fees to be paid to appoint counsel when the supreme court exercises jurisdiction over family court matter "whereby, if such proceedings were pending in family court, such court would be required by [section 262] of the family court act to appoint counsel")
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