State v. Duffy

Defendant appeals the revocation of his probation and the imposition of the previously suspended portion of a prison sentence. Defendant makes two arguments on appeal: first, that the conduct for which probation was revoked, failure to participate in psychotherapy, did not violate any condition of probation; and second, that the lower court, by allowing defendant to speak for himself at the probation hearing, granted an invalid waiver of counsel. We disagree with defendant on both of his arguments and affirm the revocation of probation.

Defendant pled guilty to a charge of sexual assault, for…