Waivers of Counsel at Probation Violation Hearings
In North Carolina a probationer has a statutory right to counsel at a probation violation hearing. G.S. 15A-1345(e); G.S. 7A-451(a)(4). The probationer can also waive the right to assistance of counsel and proceed pro se, Faretta v. California, 422 U.S. 806 (1975), but before that can happen the trial court must determine that the waiver … Read more