State v. Reed

Defendant appeals a judgment extending his probation after a hearing in which defendant appeared pro se, contending that the trial court erred in allowing him to waive counsel without advising him of the risks of representing himself. We conclude that the trial court erred in failing to advise defendant of the risks of self-representation and reverse.

In February 2008, defendant, who was then age 18, pleaded guilty to the crime of contributing to the sexual delinquency of a minor, ORS 163.435, a Class A misdemeanor. Defendant was represented by counsel. The court suspended sentence and imposed…