State v. Ashbaugh

767 Argued and submitted September 24, 2020, reversed and remanded February 24, 2022 STATE OF OREGON, Plaintiff-Respondent, v. BRIAN CODY ASHBAUGH, Defendant-Appellant. Marion County Circuit Court 18CR08083; A168108

505 P3d 1015

In this criminal case, defendant appeals from a judgment of conviction for harassment, ORS 166.065, challenging the trial court’s failure to conduct a col- loquy to determine whether he could waive his right to counsel and the court’s denial of his motion for self-representation. Held: The Court of Appeals concluded that it could not determine the basis on which the…