Does a defendant need counsel at every step of the proceedings?

It is undisputed that a criminal defendant " 'requires the guiding hand of counsel at every step in the proceedings against him' " ( Gideon v. Wainwright, 372 U.S. 335, 345, 83 S.Ct. 792, 9 L.Ed.2d 799 [1963], quoting Powell v. Alabama, 287 U.S. 45, 69, 53 S.Ct. 55, 77 L.Ed. 158 [1932] ). But the majority's bare conclusion that any arraignment conducted without the presence of counsel renders the proceedings a violation of the Sixth Amendment flies in the face of reality.

[15 N.Y.3d 31]