446 (1984). 32 . Evitts, 469 U.S. at 392-93, 105 S.Ct. at 834; Douglas v. Cal, 372 U.S. 353, 357-58, 83 S.Ct. 814, 816-17, 9 L.Ed.2d 811(1963). 33 . Douglas, 372 U.S. at 355-58, 83 S.Ct. at 815-17. 34 .Id. at 358, 83 S.Ct. at 817. 35 . Evitts, 469 U.S. at 393-97, 105 S.Ct. at 834-37. 36 . Id. at 400-01, 105 S.Ct. at 838. 37 . Id. at 396, 105 S.Ct. at 836. 38 . See M.L.B., 519 U.S. at 110-11, 117 S.Ct. at 560-61; Douglas, 372 U.S. at 358, 83 S.Ct. at 817; Evitts, 469 U.S. at 396, 400-01, 105 S.Ct. at 836, 838. 39 . Lassiter, 452 U.S. at 26-27, 101 S.Ct. at 2159-60. 40 . Id. at 27, 101 S.Ct. at 2159 (citing Mathews, 424 U.S. at 335, 96 S.Ct. at 903). 41 . Id. at 27, 101 S.Ct. at 2159-60. 42 . Id. at 27, 101 S.Ct. at 2160. 43 . Santosky, 455 U. (Tex.App.-San Antonio 2000, pet. denied) (<HOLDING>). 64 . S.C.D. v. Etowah County Dep’t of Human
holding indigent mothers due process rights were not violated by trial courts failure to appoint attorney ad litem for her until six months after parental termination suit was filed against her where counsel was appointed giving mother a year to prepare for trial when department of protective and regulatory services made clear its intent to pursue dualtrack of both termination and reunification holding that though the mother admitted that there were grounds to support termination of her parental rights the benefits of allowing the mothers relationship with her teenage daughter to continue were too palpable and the benefits of severing it too speculative for us to agree that the state had shown by clear and convineing evidence that termination was in the best interest of the child holding that the recommendations of the childrens caseworker and guardian ad litem coupled with evidence of the mothers extensive drug history her incompletion of courtordered services and testimony that the children were happy and doing well in their foster homes were sufficient for the trial court to determine that termination of parental rights was in the childrens best interest holding mothers due process rights were not violated when her appointed counsel was allowed to withdraw and hearing was held without mother because the record showed mother did not inform counsel of her whereabouts after moving thereby frustrating counsels efforts to contact her and because mother was properly served with notice of the termination hearing recognizing that the department is required to present clear and convincing evidence to support termination of a parents parental rights