State v. Wilson

Summary

The court affirmed the revocation of Wilson’s probation and resentencing after concluding that his right to counsel at a probation revocation hearing arises from a procedural rule rather than the Sixth Amendment. Applying a clearly erroneous standard, the court held the record supported the district court’s finding that Wilson knowingly, intelligently, and voluntarily waived counsel after being repeatedly advised of his right to counsel, the availability of appointed counsel, and the potential for substantial jail time.