Lawal v. State

Judge Arnold Shulman.

The appellant was convicted of misdemeanor theft by shoplifting and was sentenced to 12 months probation, conditioned upon payment of a $300 fine and performance of 50 hours of community service. He represented himself at his trial, which was conducted without a jury, and is also acting pro se on appeal.

1. The appellant appears to contend in his brief that he was denied his right to counsel at trial. The Sixth Amendment right to counsel applies in a criminal prosecution only where the defendant is sentenced to actual imprisonment. See Scott v. Illinois, 440 U. S. 367 (99…