Brandon Torregano’s probation was revoked after he appeared without counsel at the revocation hearing. The Court of Appeals of Georgia held that the record required the trial court to determine whether Torregano was entitled to appointed counsel and a new hearing. The court also held that the trial court could not revoke more than five years of probation under the governing statute, an error the State conceded. It vacated the revocation order and remanded for the counsel determination and, if necessary, resentencing. The court noted that the record contained uncertainty about whether a substance-abuse condition was general or special, an issue affecting the consequences of any violation.