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Keywords

defendantlawyerappealhearingtrialmotionprobationparoledue process
statutehearingprobationparoledue process

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Wood v. Georgia, 450 U.S. 261, 101 S.Ct. 1097, 67 L.Ed.2d 220

Facts

Petitioners, former employees of an adult movie theatre and bookstore, were convicted of distributing obscene materials and sentenced to probation with conditions that included making monthly installment payments toward substantial fines. After failing to make these payments, a revocation hearing was held where the petitioners claimed they were unable to pay and expected their former employer to cover the fines. The trial court denied their motion to modify probation conditions and revoked their probation, leading to their appeal.

Petitioners, former employees of an “adult” movie theatre and bookstore, were convicted of distributing obscene materials in violation of a Georgia statute and received fines and jail sentences but were placed on probation on the condition that they make monthly installment payments toward the satisfaction of their fines.

Issue

Whether it is constitutional under the Equal Protection Clause to imprison a probationer solely because of his inability to make installment payments on fines.

whether it is constitutional under the Equal Protection Clause to imprison a probationer solely because of his inability to make installment payments on fines.

Rule

Due process protections apply to parole and probation revocations, and a defendant has a right to representation free from conflicts of interest.

Due process protections apply to parole and probation revocations.

Analysis

The court found that the possibility of a conflict of interest was sufficiently apparent at the time of the revocation hearing, as the petitioners were represented by a lawyer who was also paid by their employer. This situation raised concerns about whether the counsel's divided loyalties influenced the decisions made during the trial and revocation hearings, potentially violating the petitioners' due process rights.

If counsel was influenced in his basic strategic decisions by the employer's interest, petitioners' due process right to representation free from conflicts of interest was not respected at the revocation hearing, or at earlier stages of the proceedings.

Conclusion

The Supreme Court vacated the judgment and remanded the case for further findings regarding the potential conflict of interest and its impact on the petitioners' due process rights.

Held: This is an inappropriate case in which to decide the equal protection question.

Who won?

The petitioners prevailed in the Supreme Court, as the court recognized the potential due process violation stemming from their counsel's conflict of interest.

Petitioners in this case are three persons who were convicted of distributing obscene materials and sentenced to periods of probation on the condition that they make regular installment payments toward the satisfaction of substantial fines.

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