Does a defendant have a right to counsel at a sentencing hearing?

"A criminal defendant has a constitutional right to counsel at all critical stages of a criminal prosecution, including sentencing." (People v. Doolin (2009) 45 Cal.4th 390, 453.) " ' "The determination whether the hearing is a 'critical stage' requiring the provision of counsel depends . . . upon an analysis 'whether potential substantial

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prejudice to defendant's rights inheres in the [particular] confrontation and the ability of counsel to help avoid that prejudice.' " [Citation.]' [Citation.] ' "[T]he essence of a 'critical stage' is . . . the adversary nature of the proceeding, combined with the possibility that a defendant will be prejudiced in some significant way by the absence of counsel." ' " (People v. Rouse (2016) 245 Cal.App.4th 292, 297.)