State v. Eichler
In State v. Eichler, 25 Utah 2d 421, 483 P.2d 887, 889 (Utah 1971), the Court held that impecunious defendants were entitled to court-appointed counsel at probation revocation hearings.
The Court stated:
"It is in accordance with the assurance of the Utah State Constitution that an accused be provided with the assistance of counsel at every important stage of the proceedings against him. Inasmuch as . . . a hearing involves the possibility of changing the defendant's status from one of being at liberty to one of being in confinement, it does no particular violence to one's sense of justice that it be regarded as an important stage of the proceeding against him at which he should have the assistance of counsel if he so desires." Id.