State v. Probst

Defendant appeals her conviction for felony driving under the influence of intoxicants (DUII). ORS 813.010(5). The charge was elevated to a felony because she had been convicted of misdemeanor DUII three times within the previous 10 years. Defendant filed a motion in limine to exclude one of the prior convictions, arguing that she had not validly waived her right to counsel in that case because there was no evidence that she adequately understood the risks of self-representation. The trial court concluded that her waiver was valid and denied the motion. After a stipulated facts trial, the…