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).
Court Rule or Initiative, Termination of Parental Rights (State) - Birth Parents
R.I. Juv. P. Rule 18(c) specifies that upon a filing of a petition for termination of parental rights, "A preliminary hearing shall be held on said petition for the court to: (4) Appoint an attorney to represent the parent(s) and any person having such care or custody of such child when said parent(s) or custodian are unable to afford such representation …" In In re Bryce T., 764 A.2d 718, 721 (R.I. 2001), the Rhode Island Supreme Court cited to Lassiter v. Dep't of Social Services, 452 U.S. 18 (1981) and noted that, "Despite the lack of a constitutional mandate, Rule 18(c) of the Family Court Rules of Juvenile Proceedings provides that "[a] preliminary hearing shall be held on [a petition for involuntary termination of parental rights] for the court to * * * (4) Appoint an attorney to represent the parent(s) and any person having such care or custody of such child when said parent(s) or custodian [is] unable to afford such representation." The court's phrasing makes it appear that it viewed the right to counsel as absolute, not discretionary.
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