State v. Richardson

Defendant appeals from a judgment of conviction for perjury, ORS 162.065, asserting that the trial court erred in proceeding without ascertaining whether defendant had voluntarily waived his right to counsel. Defendant argues, particularly, that the court was obligated to apprise defendant of the risks of self-representation before ruling on pretrial motions that he had filed pro se, but that the court failed to do so. We reverse and remand for a new trial.

On February 21,1997, defendant was arraigned. At the arraignment, the court advised defendant of the charges against him and discussed…