In Alabama v. Shelton, 535 U.S. 654, 122 S.Ct. 1764, 1767, 152 L.Ed.2d 888 (2002) the Court considered whether a defendant sentenced to a suspended sentence of imprisonment has a Sixth Amendment right to counsel. Shelton was convicted of third-degree assault in Alabama state court and was sentenced to a suspended 30-day prison sentence, two years' unsupervised probation, and monetary penalties. See id. at 1767-68. The Court held that a suspended sentence is a "term of imprisonment" requiring counsel under Argersinger v. Hamlin, 407 U.S. 25, 37, 92 S.Ct. 2006, 32 L.Ed.2d 530 (1972) and its progeny. See id. at 1767. The Court explained that "a suspended sentence is a prison term imposed for the offense of conviction. Once the prison term is triggered, the defendant is incarcerated not for the probation violation, but for the underlying offense." Id. at 1770.