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
Wyo. Stat. Ann. § 14-3-211(a) provides that "The court shall appoint counsel to represent any child in a court proceeding in which the child is alleged to be abused or neglected. Any attorney representing a child under this section shall also serve as the child's guardian ad litem unless a guardian ad litem has been appointed by the court." See DB v. MM (In re Parental Rights to Child X), 617 P.2d 1078, 1079 (Wyo. 1980) (if child not appointed attorney to represent child's best interests in abuse/neglect court proceedings, then proceedings are fatally defective and substantive issues must be remanded to repair error).
When a child is taken into temporary protective custody, placed into detention, or placed into shelter care, a shelter care or informal detention hearing must be held as soon as reasonably possible. Wyo. Stat. Ann. §§ 14-3-409(a), 14-6-409(a), 14-6-209(a). In said hearings, the judge must advise the child's parents, guardian, or custodian of their right to counsel. Wyo. Stat. Ann. §§ 14-3-409(b)(ii), 14-6-409(b)(ii), 14-6-209(b)(ii).
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