California, United States of America
The following excerpt is from People v. Mancillas, H041522 (Cal. App. 2016):
Defendant relies on People v. Vickers (1972) 8 Cal.3d 451, which established that a probationer has a due process right to be "heard in person" at a probation revocation hearing. (Id. at p. 459.) Defendant also cites to People v. Coleman (1975) 13 Cal.3d 867 for the proposition that a probationer has the right to be present at a probation revocation hearing, even if the basis for the revocation is a conviction of a new offense, "unless the probationer waives his right to a formal revocation hearing." (Id. at p. 895, fn. 22.)
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