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, Abuse/Neglect/Dependency - Children
33 V.S.A. § 5112 states, "The court shall appoint an attorney for a child who is a party to a proceeding brought under the juvenile judicial proceedings chapters." Dependency proceedings are part of juvenile judicial proceedings, as per 33 V.S.A. § 5102(14), and a child is a "party" to a dependency proceeding as per 33 VSA 5102(22). See also Vt. R. Fam. P Rule 6(b) ("In proceedings under 33 V.S.A. Chapter … 53 [children in need of care of supervision], the court shall assign counsel pursuant to Administrative Order No. 32 to represent the child unless counsel has been retained by that person.")
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