dissenting.
Because I do not believe that Webb was adequately put on notice of the consequences *1347of his having an inappropriate attitude toward therapy, I respectfully dissent. At the revocation hearing the court stated as its reason for revoking probation that Webb had failed to “accept responsibility for his criminal acts and to be involved in good faith counseling, and denial is not being involved in good faith counseling.” The conditions of Webb’s probation include a requirement that he “undergo sex abuser counseling/treatment to the satisfaction of the probation officer.” Webb went to see a sex abuse counselor, who was suggested by his probation officer, for an evaluation. The counselor concluded, following the single evaluation session, that Webb would not benefit from therapy and that he (the counselor) was not going to “waste [his] time” trying to help Webb. The counselor stated in a letter that in his experience working with clients who are in denial is “a losing proposition to everyone involved.” After receiving the evaluation Webb’s probation officer informed Webb that he needed to be in counseling. Webb told the probation officer that he didn’t feel that he needed counseling. Following the probation officer’s subsequent motion for revocation Webb attended a counseling session with a different counselor. When Webb discovered that the counselor was a substance abuse counselor and not licensed as a sex abuse counselor he stopped seeing that counselor. At the revocation hearing Webb expressed his desire to be in counseling numerous times. He testified alternatively that he believed he would benefit from counseling and that he felt that he was innocent of the crime to which he pleaded guilty.
The loss of liberty entailed in the revocation of probation is a serious deprivation requiring the probationer to be accorded due process. Gagnon v. Scarpelli, 411 U.S. 778, 781-82, 98 S.Ct. 1756, 1759-60, 36 L.Ed.2d 656 (1973); see also State v. Maier, 423 A.2d 235, 238 (Me.1980) (recognizing that a probationer’s interest in continued freedom is within the meaning of the “liberty or property” language of the Fourteenth Amendment to the United States Constitution and of Article I, section 6-A of the Maine Constitution). Fair warning of conduct that may result in revocation is an integral requirement of due process in probation revocation proceedings. United States v. Gallo, 20 F.3d 7, 11 (1st Cir.1994) (failure to undergo inpatient treatment warranted revocation where probation condition stated “continue to submit to proper psychiatric treatment, inclusive of medication,” and both defendant’s probation officer and the court gave repeated warnings that failure to do so would result in revocation). As we have previously said, “basic fairness dictates that a probationer be aware of the rules governing probationary status....” State v. Thomas, 538 A.2d 284, 286 (Me.1988).
Webb was never told, and the condition of his probation quoted above does not give warning, that to begin therapy “in denial” would result in revocation. Before the revocation hearing began, in a discussion about the State’s ability to help Webb with the cost of counseling, the probation officer stated that “any place that [the State] would fund would not be a counselor that takes people that are in denial....” Such a statement necessarily implies that there are counselors who will treat people who are in denial.
In State v. Woveris, 138 N.H. 33, 635 A.2d 454, 455 (1993), the defendant had pleaded guilty to two counts of felonious sexual assault and as a condition of probation was required to “participate in sex offender treatment.” The defendant was subsequently evaluated at two treatment centers. Id. He was refused admittance into either program due to his denial of culpability. Id. The State then filed a violation of probation report. At the hearing the State argued that the defendant’s failure to “meaningfully participate,” as evidenced by his refusal to admit culpability, constituted sufficient grounds on which to revoke probation. Id. The defendant argued that “meaningful participation” was not clearly required by the terms of his conditions of probation. Id. The court agreed that the State had failed to establish a violation, and modified the defendant’s probation to include a requirement of “meaningful participation.” Id. Following the revocation hearing the defendant was admitted into a treatment program and attended all fourteen of the program’s scheduled sessions. Id. He was terminated from further participation in the program, however, because his *1348continued denial of responsibility made him not amenable to outpatient treatment. Id. The State then filed a second violation of probation report. The New Hampshire Supreme Court affirmed the probation revocation, ruling that the first hearing, the subject of which was entirely a clarification of what was required of the defendant in treatment, coupled with the probation officer’s subsequent discussion with the defendant of the need to admit responsibility for his conduct, was sufficient notice to the defendant that his failure to do so might result in revocation. Id. at 455-56.
In my view, the court in this case should have done what the court in Woveris did after the State’s first violation of probation report. That is, if the probation officer and the court determined that revocation could result from Webb’s refusal to admit his own culpability, the court should have modified Webb’s conditions of probation to include notice that “denial” would lead to such a result.1 As it is, Webb’s freedom has been taken away because, before he was even able to get counseling, he displayed an attitude that he did not know could result in such a loss. I would vacate the revocation and remand to the Superior Court for consideration of the motion for probation revocation in light of the opinion herein.
. The court is authorized, pursuant to 17-A M.R.S.A. § 1202(2) (Supp.1995), to modify or add to, as limited by 17-A M.R.S.A. § 1204 (1983 & Supp.1995), the requirements of probation.