Donaldson v. State

The appellant, Johnny Ray Donaldson, was convicted of two counts of second-degree arson. The trial court sentenced him to serve terms of ten years in prison, but suspended the sentences and placed him on probation for five years. On March 15, 2006, the appellant's probation officer filed an "Officer's Report on Delinquent Probationer." After conducting a revocation hearing, the circuit court revoked the appellant's probation. This appeal followed.

The appellant argues that the circuit court erred by not appointing counsel to represent him during the revocation proceedings.1

"`[T]here is no…