The defendant’s right to counsel was violated when the trial court denied his request for representation at sentencing. The defendant here had waived his right to counsel earlier in the proceedings, but requested the assistance of an attorney at sentencing. The Ninth Circuit held that the state court violated clearly established federal law when it denied that request, holding that the federal circuits have interpreted the Supreme Court’s Sixth Amendment precedent to mean that the right to counsel is so integral to the fair administration of our justice system that a defendant who has waived his right to counsel may nonetheless revoke that waiver for purposes of a sentencing proceeding, and the request for counsel may not be denied without a sufficient reason. Because of the fundamental importance of the right to counsel, the defendant need not establish prejudice, and is entitled to a new sentencing hearing.