constitutional right to effective counsel during parole revocation hearing
How later courts described this case
- constitutional right to effective counsel during parole revocation hearing
Written by the judges who cited it.
The opinion
SPAETH, Judge,
concurring:
I concur, but note that until Commonwealth v. Stratton, 235 Pa.Super. 566 , 344 A.2d 636 (1975) (JACOBS, J., filed a dissenting opinion in which WATKINS, P. J., joined), is overruled, issues based on defects in (or, as here, the non-existence of) a Gagnon II hearing are not waived by failing to object at the probation revocation hearing. It is therefore unnecessary here to reach appellant’s argument on ineffectiveness of counsel.