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
I.C. § 16-2009, which is part of Chapter 20 ("Termination of Parental Rights") provides in relevant part that “[the] parent . . . shall be notified as soon as practicable after the filing of a petition and prior to the start of a hearing of his right to have counsel, and if counsel is requested and the parent . . . is financially unable to employ counsel, counsel shall be provided.” While adoptions are conducted under Chapter 15 and not Chapter 20, I.C. § 16-2007(1) states that for a termination of parental rights proceeding,
[t]he petitioner shall give notice to any person entitled to notice under section 16-1505, Idaho Code [Notice of Adoption Proceedings], the authorized agency having legal custody of the child and the guardian ad litem of the child and of a parent. The petitioner shall give notice to the Idaho department of health and welfare if the petition for termination was not filed in conjunction with a petition for adoption or by an adoption agency licensed by the state of Idaho.
This suggests the adoption and termination proceedings are intertwined.
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