State v. Alt

Defendant waived his right to counsel in a probation revocation hearing and represented himself. The record does not show that the trial court advised him of the consequences of a revocation or of the possible consequences and pitfalls of representing himself. See State v. Busby, 107 Or App 368, 812 P2d 14 (1991). A trial court must make at least a minimum inquiry into whether a defendant understands the consequences of a waiver of counsel before allowing him to proceed without counsel. State v. Boswell, 92 Or App 652, 760 P2d 276 (1988). The state concedes that defendant was not advised and…