Kemp v. Spradlin

Clarke, Justice.

This is a habeas corpus case in which the writ was granted by the trial court. We affirm.

Spradlin was given probation after pleading guilty to burglary in *8301980. He had no legal counsel. Again in 1981, without legal counsel, he pled guilty to two counts of violating the Georgia Controlled Substances Act. His probation in the burglary case was revoked during a hearing at which he was also unrepresented.

The issue is whether the accumulation of proceedings, each of which could result in deprivation of liberty without legal assistance, is sufficient grounds to support the…