Mempa v. Rhay

Mempa (defendant/petitioner) was convicted of joyriding and placed on probation for two years, conditioned on 30 days in county jail, with sentencing deferred. Four months later, the state moved to revoke his probation after he was involved in a burglary. At the revocation hearing, 17-year-old Mempa appeared with his stepfather but without counsel, and no one asked whether he wanted counsel appointed. Mempa admitted involvement in the burglary at the hearing. His probation was revoked and he was sentenced to 10 years.