Harris v. State

Appellant, Luis Harris [“Harris”], appeals his judgment and sentence after a violation of probation.

On April 28, 2011, the trial court held a hearing on Harris’s violation of probation. Prior to the hearing, the trial court offered Harris appointed counsel. Harris refused counsel and decided to represent himself. After a contentious hearing, the trial court found that Harris violated probation and immediately sentenced him. However, prior to sentencing Harris, the trial court did not renew the offer of counsel.

On appeal, Harris correctly asserts that he is entitled to a new sentencing because…