State v. Culver

Defendant was convicted of several felonies stemming from an alleged assault. He appealed, arguing that the trial court failed adequately to warn him of the risks inherent in waiving his right to counsel. The state concedes that the record does not demonstrate that defendant’s waiver was made knowingly. Thus, the sole issue on appeal is whether we should remand to allow the trial court to conduct an inquiry as to the validity of the waiver or remand for a new trial. Because the waiver resulted in prejudice to defendant, we remand for a new trial.

Appellant was indicted for sexual abuse in the…