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 (Private) - Birth Parents
Indigent parents have a right to counsel in contested adoption cases. Parents under the age of 18 may not waive their right to counsel, but parents over the age of 18 may waive the right “if the court is satisfied that the waiver is knowingly and voluntarily made.”
For parents over the age of 18, if the parent is: (i) entitled to representation by counsel pursuant to §§ 48.23(2), (2g) or (2m); (ii) counsel is not knowingly and voluntarily waived; and (iii) it appears that the parent is unable to afford counsel in full or if the parent so indicates to the court, the court must refer the parent to the authority for indigency determinations under § 977.07(1). Wis. Stat. Ann. § 48.23(4). In any other situation under § 48.23 in which a person “has a right to be represented by counsel or is provided counsel at the discretion of the court, competent and independent counsel shall be provided and reimbursed in any manner suitable to the court regardless of the person's ability to pay … .” Id. Parents subject to a petition of termination of parental rights under §§ 48.25 or 48.835 must be notified of their right to counsel in the summons, or if the parent cannot be served, through constructive notice. Wis. Stat. Ann. §§ 48.42(3)(b), 48.42(4)(c)(2).
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