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
Wis. Stat. § 48.235(1)(c) provides that “The court shall appoint a guardian ad litem for any child who is the subject of a proceeding to terminate parental rights, while subsection (3) adds that “If the guardian ad litem determines that the best interests of the person are substantially inconsistent with the wishes of that person, the guardian ad litem shall so inform the court and the court may appoint counsel to represent that person.”
In Dunn Cnty. HHS v. C.R.R. (In re A.M.R.), No. 2015AP1771, 880 N.W.2d 183, ¶¶ 33-37 (Wis. Ct. App. Apr. 13, 2016), the court held that the mandatory child counsel appointment provisions of § 48.23(1m) apply only to CHIPS proceedings, not termination of parental rights proceedings; for the latter, children are only entitled to a guardian ad litem (who must be an attorney).
Cite: Wis. Stat. § 48.235(3)
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: yes