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) - Children
10 Okla. St. Ann. § 7505–1.2(A)(1) of the Oklahoma Adoption Code states that:
In a proceeding pursuant to the Oklahoma Adoption Code, the court shall appoint an attorney for a minor in a contested proceeding pursuant to the Oklahoma Adoption Code and may appoint an attorney for a child in an uncontested proceeding or appoint an attorney for the child to examine all expenses and attorney fees presented to the court for approval.
Additionally, in In re S.A.W., 856 P.2d 286, 289 (Okla. 1993), the court extended In re T.M.H., 613 P.2d 468, 470-71 (Okla.1980) (recognizing statutory right to independent counsel for children in state-initiated terminations) to private parental termination actions, although it is unclear whether T.M.H. is still good law given that the statute now governing (Okla. Stat. tit. 10A, § 1-4-306) does not mention termination of parental rights 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: no