Taylor v. State

SCHWARTZ, Chief Judge.

The appellant was convicted of aggravated assault. In making the guidelines computation, the trial court included points under the “legal constraint” category because Taylor was on six-months’ non-reporting probation pursuant to a guilty plea on an earlier trespass charge. He claims that this was improper because the previous plea and conviction were obtained without an effective waiver of counsel. See Crigler v. State, 487 So.2d 420 (Fla. 2d DCA 1986); Pilla v. State, All So.2d 1088 (Fla. 4th DCA 1985); Hayes v. State, 468 So.2d 470 (Fla. 4th DCA 1985). We do not agree.…