State v. Jensen

CROTHERS, Justice.

[¶ 1] Randy Scott Jensen appeals the district court order revoking his probation. We reverse and remand, concluding the district court erred in allowing Jensen to represent himself at the revocation of probation hearing without first determining Jensen voluntarily, knowingly and intelligently waived his right to counsel.

I

[¶ 2] In October 2008, Jensen was sentenced to two year’s supervised probation for theft of property. The terms of Jensen’s probation required him to abstain from using non-prescribed controlled substances, to abide by all laws and to inform his probation…