Butler v. State

My colleagues state that the facts of this case are similar to Greer v. State, 690 N.E.2d 1214 (Ind.Ct.App.1998), and conclude that Butler, like Greer, waived his right to counsel because he admitted violating his probation.

The following exchange between the trial court and Butler is the entirety of the record regarding the waiver of counsel:

COURT: If it’s found you’ve violated your probation, whether you admit or it’s found at a hearing, the maximum penalty the Court can impose is the four (4) years that was suspended. The minimum is zero (0) additional days in jail. Do you understand what…