In the case of Carchman, Mercer County Prosecutor v. Nash (1984), the U.S Supreme Court ruled that a state is not required to provide counsel at a parole revocation hearing under the Sixth Amendment right to counsel clause. The defendant, Nash, had been convicted in New Jersey and was on parole when he was arrested for another crime in Pennsylvania. His parole officer filed charges against him for violating his parole conditions due to this arrest and requested an interstate detainer from Pennsylvania so that they could return him back to New Jersey after serving his sentence there. At his subsequent hearing regarding these violations, Nash did not have legal representation present which led him to file a lawsuit claiming violation of his Sixth Amendment rights. The court held that since the proceeding was non-adversarial and administrative rather than criminal in nature; it didn't trigger Sixth Amendment protections as per Gagnon v Scarpelli (1973). Therefore, states are not constitutionally obligated by the sixth amendment's right-to-counsel provision or by any other constitutional provision analyzed within this context - including Fourteenth Amendment’s Due Process Clause -  to furnish appointed counsel at every such proceeding.

In the dissenting opinion for Carchman v. Nash, Justice Brennan argued that the majority's interpretation of the Interstate Agreement on Detainers (IAD) was too narrow and did not adequately protect prisoners' rights. He contended that any detainer lodged against a prisoner should trigger IAD protections, regardless of whether it originated from a prosecutor or parole board. This broader interpretation would better serve the purpose of IAD - to minimize potential disruptions in rehabilitation programs by providing certain procedural safeguards to inmates facing charges in another jurisdiction. Furthermore, he disagreed with the majority's view that only formal charging documents could initiate these protections; instead, he believed any notice indicating an intent to bring charges should suffice. By limiting these protections as they did, Justice Brennan felt that his colleagues were undermining both fairness and efficiency within criminal justice system.