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
South Dakota grants "the child's parents, guardian, or other custodian" a statutory right to court-appointed counsel upon request in cases involving the termination of parental rights. S.D. Codified Laws § 26-7A-31 (specifying that parent must request counsel). In addition, § 26-7A-31 confers on South Dakota courts the discretion to appoint an attorney for the child or any party without request if legal representation appears necessary to protect the interests of the child. The county in which the proceeding occurs must pay for the expense of counsel in such cases, according to the manner prescribed by the court. I
Notably, S.D. Codified Laws § 26-7A-30 requires the court to notify parents of their "constitutional and statutory rights, including the right to be represented by an attorney."
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