State v. Todd

In this criminal case, defendant represented herself at trial and was convicted of several prostitution-related crimes. On appeal, she argues that her convictions should be reversed because she did not knowingly and voluntarily waive her right to counsel.1 We review for errors of law, State v. Langley, 351 Or 652, 666, 273 P3d 901 (2012), and we reverse and remand.

The procedural facts of this case are as follows. Defendant was charged by information with six counts of attempted prostitution under ORS 167.007 and ORS 161.405, and six counts of unlawful prostitution procurement activity under…