Alabama v. Shelton, 535 U.S. 654, 122 S.Ct. 1764, 152 L.Ed.2d 888 (2002) (suspended sentence that can potentially be transformed into actual incarceration is sufficient to trigger the Sixth Amendment right to counsel in misdemeanor cases).


NOTE: Misdemeanor convictions in which no sentence, or suspended sentence, to custody was imposed can still trigger immigration consequences. In these cases, the Sixth Amendment right to counsel does not apply, so post-conviction relief would not be possible on grounds of denial of counsel or ineffective assistance of counsel.