Salley v. State

Harwell, Justice:

Petitioner Linda Salley pled guilty to various crimes committed while she was on probation from a previous offense. Her probation was revoked. Petitioner sought post-conviction relief (PCR), alleging, among other things, that she did not knowingly and intelligently waive the right to counsel at her probation revocation hearing. We granted petitioner’s application for writ of certiorari to determine whether the PCR judge erred in finding petitioner validly had waived her right to counsel at the probation revocation hearing. We reverse.

I. FACTS

Petitioner pled guilty to assault…