A.G. v. State

A.G. appeals an order of disposition after he pled no contest to two counts of possession of cocaine.1 The Department of Juvenile Justice (DJJ) recommended a Level 6 disposition, but the trial judge imposed a Level 8 after the state requested it. A.G. waived counsel at the disposition hearing, and he argues on appeal that the trial court erred in proceeding to disposition without determining if his waiver was knowing and voluntary, as provided in Fla.R.Juv.P. 8.185. We agree and reverse.

The Public Defender’s Office represented A.G. at the pretrial hearing and at the plea hearing. However, at…