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
Washington provides for the appointment of counsel to indigent parents at all stages of a proceeding in which a child is alleged to be dependent, including termination of parental rights proceedings. Wash. Rev. Code § 13.34.090.2 This includes a right to counsel for non-consenting parents in private adoption proceedings where the prospective adoptive parent seeks to terminate parental rights of the natural parent. Wash. Rev. Code § 26.33.110(3)(b). However, parents who voluntarily put their children up for adoption are not entitled to the appointment of counsel. In re Adoption of Hernandez, 607 P.2d 879 (Wash. Ct. App. 1980).
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