In which case did the Court decide that probationers have a right to counsel at a deferred sentencing (probation revocation) hearing?

Question

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Mempa v. Rhay is the case in which the Supreme Court decided that probationers have a right to counsel at a deferred sentencing (probation revocation) hearing, establishing the principle that the Sixth Amendment right to counsel applies in such situations.

In Which Case Did the Court Decide That Probationers Have