Commonwealth v. Tinson

In Commonwealth v. Tinson, 433 Pa. 328, 249 A.2d 549 (1969), the Pennsylvania Supreme Court, relying on Mempa and Remeriez, held that a hearing at which the petitioner was recommitted to prison for a technical violation of his parole also required effective assistance of counsel. "The recommitment hearing determined whether or not appellant would be returned to prison. There can be no question that a proceeding at which a determination of that kind was made was a 'critical stage.'" Tinson, 433 Pa. at 334, 249 A.2d at 552.