State v. Hagstrom

Defendant appeals a judgment of conviction for one count of second-degree assault, ORS 163.175, and two counts of fourth-degree assault, ORS 163.160. On appeal, he contends, inter alia, that the trial court erred in allowing “defendant to proceed pro se without obtaining a valid waiver of counsel” and in denying his motion for judgment of acquittal (MJOA) on the count of second-degree assault. An extended recitation of the facts would not benefit the bench, the bar, or the public. For the reasons stated below, we reverse and remand.

“[B]ecause the relief for an erroneously denied MJOA — entry…