State v. Lambert

Summary

The court held that the district court violated Lambert's statutory and constitutional right to counsel by conducting the revocation dispositional hearing without counsel and without a valid waiver. Because the uncounseled resentencing occurred at a critical stage, the error was structural, and Lambert was also concretely prejudiced when the court relied on uncounseled admissions concerning additional violations. The court declined to decide whether Lambert could withdraw his admission regarding the registration violation because the record did not establish the precise statutory duty involved or provide sufficient findings.