Swift v. State

SCHEB, Judge.

Zachary Swift appeals the order revoking his probation and subsequent judgment and sentence for grand theft. Swift contends that the trial court failed to make sufficient inquiry prior to accepting his waiver of counsel at the probation revocation hearing. We agree and reverse.

Swift was originally convicted of grand theft and placed on probation for five years. The trial court adjudged him insolvent at that time. Swift subsequently failed to comply with several technical conditions of his probation. The trial court restored his probation but modified the conditions to include six…