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) - 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). And in Vermont, there is no separate termination statute; instead, termination is treated as one type of disposition for a dependency petition. See 33 V.S.A. §§ 5318(a)(5), 5113(b) (modification of dependency order). Consequently, counsel that is assigned for the dependency for either the child or parent continues through the termination phase.
It is true that 13 V.S.A. § 5232 only requires appointment in juvenile court proceedings "when the court deems the interests of justice" require it for the child. But Vt. Stat. tit. 13, § 5202 adds that the “protections provided by this chapter do not exclude any protection or sanction that the law otherwise provides." So this provision should not override the requirement of 33 V.S.A. § 5112.
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