California, United States of America
The following excerpt is from People v. Watkins, B299603 (Cal. App. 2020):
The right to counsel at a parole revocation hearing, when it exists at all, derives not from the Sixth Amendment guarantee, which does not apply to parole proceedings, but as a matter of due process. (See Gagnon v. Scarpelli (1973) 411 U.S. 778, 790
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