Bounds v. State

Phipps, Judge.

A jury found Stephen Halsey Bounds guilty of felony obstruction of a law enforcement officer. On appeal, Bounds, who represented himself at trial, argues that the trial court should have granted his motion for directed verdict of acquittal and that the court erred by accepting his waiver of counsel. We reject his first contention, but we remand for the trial court to determine whether Bounds validly waived his right to counsel.

1. In a criminal case,

alleging error based upon a trial court’s failure to grant a directed verdict of acquittal is tantamount to challenging the…