K.H. v. Jefferson County Department of Human Resources

The right of a parent in a dependency action to be represented by counsel is fundamental. R.H. v. D.N., 5 So.3d 1253, 1254-55 (Ala.Civ.App.2008); Smoke v. State Dep’t of Pensions & Sec., 378 So.2d 1149, 1150 (Ala.Civ.App.1979). I cannot agree that the record in this case indicates that the mother waived that right. Accordingly, I respectfully dissent.'