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1) Jesse Pollard pleaded guilty without counsel to driving under the influence and was sentenced to one year of probation. He argued his sentence violated his right to counsel under Alabama v. Shelton. 2) The district court rejected this argument, finding probation is not equivalent to a suspended sentence. It held Shelton only applies to suspended sentences coupled with imprisonment, not standalone probation. 3) On appeal, the Fourth Circuit affirmed, noting Shelton expressly reserved whether uncounsele

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Scribd Government Docs

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