The following excerpt is from Lopez v. Thompson, 175 F.3D 1120 (9th Cir. 1999):
In felony cases, a criminal defendant is entitled to be represented by counsel at all critical stages of the prosecution, including sentencing. Mempa v. Rhay, 389 U.S. 128, 134, 136, 88 S.Ct. 254, 19 L.Ed.2d 336 (1967). It is clear that Lopez had a Sixth Amendment right to counsel at his sentencing hearing.
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