State v. Crain

Defendant appeals his conviction for first-degree burglary. ORS 164.225. He contends that the trial court erred (1) in failing to treat his attorney’s motion to withdraw on the day of trial as defendant’s own request for substitute counsel; and (2) by including a previous fourth-degree assault conviction in his criminal history score for purposes of sentencing, because there was no showing that he was represented by counsel or validly waived counsel before entering a guilty plea in that case. We affirm.

The trial court appointed counsel to represent defendant in this case. On the morning of…