State v. Nordstrom

Michael Nordstrom made several appearances in court, without counsel, in response to charges of fourth degree assault and third degree malicious mischief. At each appearance he was advised to return with an attorney, but he never did so. Because, under the circumstances of this case, Nordstrom neither expressly nor impliedly waived his right to counsel and the record demonstrates that he did not understand the consequences of self-representation, we reverse.

In early October 1994, the State charged Nordstrom in King County District Court with fourth degree assault and third degree malicious…