Under the U.S. Constitution, a probationer is entitled to a court-appointed attorney during revocation proceedings.

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Under the U.S. Constitution, probationers are not automatically entitled to a court-appointed attorney during revocation proceedings. The Supreme Court in Gagnon v. Scarpelli, 411 U.S. 778 (1973), held that the decision to appoint counsel in probation revocation proceedings should be made on a case-by-case basis considering various factors.