Leon Elrod was convicted of selling cocaine and sentenced to life as a recidivist. He challenged the sufficiency of the evidence, jury instructions, and the use of a prior probation revocation to enhance his sentence when he may not have had counsel in that proceeding. The Georgia Court of Appeals affirmed the conviction but vacated the life sentence. The record did not establish whether Elrod had been entitled to counsel at the earlier revocation hearing or whether he knowingly waived that right. The court remanded for the trial court to obtain the prior transcript if possible or conduct an evidentiary hearing applying the relevant counsel-right factors, then impose an appropriate sentence. The court declined to treat a disposition form indicating a guilty plea as conclusive because the record also suggested that Elrod had asserted innocence and requested counsel.