Ex Parte Sanders

In per curiam opinion delivered February 28,1978 in this very case the Court ordered the trial court to hold a habeas corpus evi-dentiary hearing. To the argument of the State that Sanders “was not constitutionally entitled to counsel during the probation revocation proceedings in 1965,” the Court wrote:

“We further note that at the time of petitioner’s conviction in 1968, the law as to whether defendants were entitled to counsel during probation revocation proceedings was so unsettled1 as to hold that there was an intentional and knowing waiver of this contention due to trial counsel’s…