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
A non-consenting parent in an adoption proceeding has a right to a court appointed attorney if indigent. Or. Rev. Stat. Ann. § 109.330(4); see also Or. Rev. Stat Ann. § 109.326 (husband who is not father of child at issue in adoption proceeding has a right to appointed counsel if indigent). see also Or. Rev. Stat Ann. § 109.326 (husband who is not father of child at issue in adoption proceeding has a right to appointed counsel if indigent). In order to consent to an adoption, a parent must have been “given an explanation by an attorney who represents the person and who does not also represent the adoptive family, by the department or by an Oregon licensed adoption agency of the consequences of signing the certificate.” Or. Rev. Stat. Ann. § 109.321(2)(F).
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