In Mercer v. Hopper, the Georgia Supreme Court, in a four-sentence per curiam opinion, held that "[tihere is no right to counsel at a probation revocation hearing in Georgia." Mercer pleaded guilty to, and was convicted of, three charges of driving under the influence of intoxicants and one charge of forgery. He received a five year sentence for forgery and three 12-month sentences for the DUI charges, the latter to run consecutively, but concurrently with the forgery sentence. All sentences were ordered to be served on probation.
Potter, Robert R.
"Constitutional Law--No Right to Counsel at Probation Revocation Hearings,"
Mercer Law Review: Vol. 27
, Article 23.
Available at: https://digitalcommons.law.mercer.edu/jour_mlr/vol27/iss1/23