California, United States of America
The following excerpt is from People v. Harris, 226 Cal.App.3d 492, 277 Cal.Rptr. 36 (Cal. App. 1990):
But more basically, respondent argues regardless of the fact that appellant was convicted without the assistance of counsel or waiver of that right, the conviction can be used to revoke probation because he was guilty of the [226 Cal.App.3d 497] offense charged. Whether appellant was or was not guilty of the underlying offense is irrelevant in determining whether the unconstitutional conviction can be the basis from which additional penal sanctions flow. (People v. Coffey, supra, 67 Cal.2d at pp. 214-215, 60 Cal.Rptr. 457, 430 P.2d 15.)
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