J.A.H. v. Calhoun County DHR
In J.A.H. v. Calhoun County DHR, 846 So. 2d 1093, 1095 (AlaCivApp 2002), the father had requested court appointed counsel at the initial phase of the proceedings and had been found financially qualified for such representation. Id. at 1094.
However, due to a conflict of interest court appointed counsel was allowed to withdraw and no replacement counsel was appointed by the trial court. Id.
Father never rejected or discharged his court appointed attorney, nor did he waive his statutory right to counsel by his actions. Id.