Final answer:
The case that established limited right to counsel for parolees during revocation proceedings is 3)Morrissey v. Brewer, a key Supreme Court decision.
Step-by-step explanation:
The case that held that parolees have a limited right to counsel during revocation proceedings is Morrissey v. Brewer. This 1972 Supreme Court decision importantly shaped the due process rights of individuals on parole.
In Morrissey, the Court ruled that parolees have certain rights when facing parole revocation, including the right to be heard and to show why parole should not be revoked.
And while they do not have the absolute right to counsel, they have a limited right to assistance of counsel in some circumstances.