Dean v. State

After Remand from the Alabama Supreme Court

In Dean v. State, 57 So.3d 169 (Ala.2010), the Alabama Supreme Court reversed this Court’s decision in Dean v. State, 57 So.3d 164 (Ala.Crim.App.2009), and held that a claim that a lower court “refused to appoint counsel to represent an indigent probationer at a probation-revocation hearing” did not have to be preserved for appellate review. The Supremé Court also held, contrary to this Court, that the circuit court did not err in refusing to appoint counsel to represent Dean at his probation-revocation hearing because, it said, the issues involved…