Osbey v. State

JUSTICE FEW :

Robert Osbey pled guilty to criminal charges without counsel. He later applied for post-conviction relief (PCR) on the ground he did not waive his right to counsel. We reverse the denial of his PCR claim because the record does not reflect a valid waiver of Osbey's right to counsel. In particular, the plea court did not ensure Osbey was aware of the dangers of self-representation. We remand to the court of general sessions for a new trial.

I. Facts and Procedural History

The State charged Osbey with two counts of trafficking in cocaine base and one count of possession with intent…