Vollmer v. State

KHOUZAM, Judge.

Jon Vollmer appeals a final judgment adjudicating him guilty of criminal contempt and sentencing him to six months in jail: Vollmer argues that the trial court reversibly erred by (1) failing to adequately inquire into his request to represent himself prior to the contempt hearing and (2) failing to renew the offer of counsel prior to sentencing. We hold that the trial court’s inquiry at the contempt hearing was sufficient and therefore affirm the adjudication of guilt. But because Vollmer was entitled to a renewal of the offer of counsel at sentencing, we reverse and remand…