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 (State) - Birth Parents
In most states, adoption proceedings are separate from termination of parental rights proceedings stemming from an abuse or neglect finding. However, it appears that in Pennsylvania, the state uses the Adoption Act to file termination of parental rights petitions based on abuse/neglect. See, e.g., In re Adoption of J.N.F., 887 A.2d 775, 778 (Pa. Super. Ct. 2005). In turn, the Adoption Act requires the court to appoint counsel for a parent in an involuntary termination proceeding if, upon petition of the parent, the court determines that the parent is unable to pay for counsel or if payment would result in substantial financial hardship. 23 Pa. Cons. Stat. Ann. § 2313(a.1).
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