State v. Brown

*158EDMONDS, J.

Defendant appeals from convictions for assault in the fourth degree, attempted assault in the fourth degree, and harassment. ORS 163.160; ORS 166.065. Defendant represented himself without the benefit of a lawyer throughout the proceedings that led to the conviction. On appeal, he argues that the trial court erred in accepting his waiver of counsel, because it did not determine that he understood the dangers and disadvantages of self-representation. Therefore he argues that his waiver of counsel was invalid under Article I, section 11, and the Sixth Amendment and that his…