Final answer:
The Gagnon v. Scarpelli decision held that probationers facing revocation have due process rights, which include two hearings, a written notice of violations, and disclosure of evidence. The right to legal counsel was not guaranteed but criteria were established for when counsel might be necessary.
Step-by-step explanation:
Important Findings in Gagnon v. Scarpelli:
The case of Gagnon v. Scarpelli, decided in 1973, built upon the landmark Supreme Court decision of Gideon v. Wainwright. In Gideon v. Wainwright, the Court determined that the accused has the right to legal counsel, regardless of their ability to pay, fundamentally altering the criminal justice landscape to favor due process. The Gagnon v. Scarpelli decision specifically addressed the issue of probation revocation, and established that defendants have certain due process rights during a probation revocation hearing.
The Court held that a probationer should receive two hearings, which are crucial to the revocation process: a preliminary hearing to determine if there is probable cause to believe that a probation violation occurred, and a more comprehensive hearing prior to making the final revocation decision. Moreover, the Court concluded that the probationer is entitled to a written notice of the claimed violations, disclosure of the evidence against them, an opportunity to be heard in person, and to present witnesses and documentary evidence. Although Gagnon v. Scarpelli did not categorically entitle the probationer to legal counsel, it did establish criteria for when the appointment of counsel might be necessary, such as, if the probationer claims that he or she did not commit the alleged violation, or if there are complex legal issues to be resolved.