State v. Garibaldi

OPINION

HUSPENI, Judge. *

Appellant challenges his conviction for felony test refusal, arguing that the district court did not obtain an adequate waiver from him of his right to counsel before proceeding with a bench trial on stipulated facts. Appellant argues that a written waiver of the right to counsel was required and that a comprehensive inquiry on the record did not occur. Appellant also argues that the district court erred by allowing private counsel who had already filed a certificate of representation to withdraw without making any appearance in court or filing a motion. Because the…