H.A.G. v. State

FULMER, Chief Judge.

H.A.G. appeals from a revocation of probation. Because the trial court did not conduct an inquiry into H.A.G.’s waiver of counsel until after the court elicited an admission to the violation of probation, we reverse.

The record does not reflect any discussion of H.A.G.’s right to counsel until after the trial court explained the allegations and asked if H.A.G. wanted to admit or deny. H.A.G. stated that he would admit the violations. The court then conducted a plea colloquy and asked if H.A.G. understood that he was giving up his right to an attorney for the purpose of the…