Robinson v. Ignacio, 360 F.3d 1044 (9th Cir. March 10, 2004) (Sixth Amendment right to counsel violated when trial court denied timely request for representation at sentencing on erroneous basis that once waived, the right to counsel cannot be re-asserted).
http://caselaw.lp.findlaw.com/data2/circs/9th/0217298p.pdf