Cunningham v. State

Appellant, who represented himself at his violation of probation hearing, argues the trial court violated his right to counsel by failing to renew an offer of counsel before imposing sentence. See Traylor v. State, 596 So.2d 957, 968 (Fla.1992) (stating that a defendant has the right to assistance of counsel at each crucial stage of the proceedings); Lewis v. State, 31 So.3d 944, 945 (Fla. 1st DCA 2010) (holding that Florida Rule of Criminal Procedure 3.111(d)(5) requires trial court to renew offer of counsel at sentencing phase); Travis v. State, 969 So.2d 532, 533 (Fla. 1st DCA 2007)…