Chamlee v. State

I concur fully in Divisions 1, 2 and 4 of the opinion, and while agreeing with the result reached in Division 3,1 am compelled to offer the following comments. The broad rule that an indigent probationer has no right to the assistance of counsel at a revocation hearing has been modified by the United States Supreme Court in Gagnon v. Scarpelli, 411 U. S 778 (93 SC 1756, 36 LE2d 656) (1973), holding that counsel at a probation revocation hearing should be determined on a case-by-case basis applying certain general guidelines as to whether the assistance of counsel is constitutionally…