In Re Ex Parte State of Alabama (Nickolas L. Dean v. State of Alabama).

Summary

The Alabama Supreme Court reversed the Court of Criminal Appeals and remanded, holding that (1) a claim that a trial court failed to inform a probationer of the right to request counsel need not be preserved for appellate review, and (2) the circuit court did not err in refusing to appoint counsel because the probationer’s mitigating reasons were not complex or difficult to develop, so the revocation stood.