State v. Fiala

Defendant appeals from convictions for sexual abuse in the first degree. ORS 163.425. He argues that the trial court erred in denying his request for court-appointed counsel and in not advising him of the consequences of proceeding to trial without counsel. We reverse.

After the arraignment, defendant’s retained attorney was allowed to withdraw, and the court granted defendant’s request for a court-appointed attorney. Thereafter, the court withdrew the appointment. Defendant argues that the court abused its discretion, because its decision was based on the credit limit available to defendant…