Jackson v. State

MlKELL, Judge.

Following a bench trial, Christopher Jackson was convicted of misdemeanor battery, OCGA § 16-5-23.1, and false imprisonment, OCGA § 16-5-41, for acts directed at his girlfriend. The trial court without a hearing denied Jackson’s motion for a new trial, and this appeal followed. In the sole error raised on appeal, Jackson contends that the court erred in conducting a bench trial without first determining whether he had knowingly, voluntarily, intelligently, and personally waived his right to a jury trial. Because the record does not adequately demonstrate whether Jackson made…