Mempa v. Rhay, 389 U.S. 128 (1967) dealt with a probation revocation hearing, the United States Supreme Court held that the Sixth Amendment requires "appointment of counsel for an indigent . . . at every stage of a criminal proceeding where substantial rights of a criminal accused may be affected." Id. at 134. In Mempa v. Rhay, involved two consolidated cases applying Washington state law, sentencing had been "deferred subject to probation." (Id. at p. 130.) The petitioners pleaded guilty and were placed on probation without imposition of sentence; they were later sentenced upon revocation of probation without the benefit of counsel. (Id. at pp. 130-133.) The United States Supreme Court stated the basic rule that "appointment of counsel for an indigent is required at every stage of a criminal proceeding where substantial rights of a criminal accused may be affected." (Id. at p. 134.) It determined that a lawyer must be afforded to defendants at the deferred sentencing stage of the proceeding. (Id. at p. 137)The United States Supreme Court held a probationer was entitled to be represented by appointed counsel at a combined revocation and sentencing hearing. The court reasoned that counsel was required "at every stage of a criminal proceeding where substantial rights of a criminal may be affected" and that sentencing was one such stage. (Id., at pp. 134-137.) The court concluded that counsel must be provided at sentencing even when it is accomplished as part of a subsequent revocation proceeding. (Id., at p. 137.) In Mempa v. Rhay, the defendant was placed on probation for two years on the condition that he first spend thirty days in jail. The imposition of sentence was deferred. Id. 131. About four months later, Mempa was involved in a burglary, and a revocation hearing was held. The court immediately entered an order revoking petitioner's probation and then sentenced him to ten years in the penitentiary. Id. The United States Supreme Court in Mempa held that a probationer is entitled to be represented by appointed counsel at a combined revocation and sentencing hearing unless probationer was sentenced at the time of the trial or plea.