The following excerpt is from U.S. v. Pugliese, 805 F.2d 1117 (2nd Cir. 1986):
Sentencing is nonetheless a critical stage in a criminal case where due process protects a convicted person as it does an accused at trial. A convicted defendant has a right to procedural safeguards, such as the right to counsel, see Mempa v. Rhay, 389 U.S. 128, 134, 88 S.Ct. 254, 256, 19 L.Ed.2d 336 (1967). As a consequence, sentencing no longer stands like an island separate from the mainland of criminal law.
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