State v. Erb

A jury convicted defendant of pointing a firearm at another, ORS 166.190, and menacing, ORS 163.190. Defendant argues that the trial court committed reversible error by allowing her to proceed without counsel.1 We agree, and, therefore, we reverse and remand.

The relevant facts are procedural and undisputed. On February 19,2010, defendant was charged with pointing a firearm at another, ORS 166.190; menacing, ORS 163.190; and disorderly conduct in the second degree, ORS 166.025. On February 22, 2010, the trial court ordered appointment of counsel, subject to verification of financial…