State v. Howard

Defendant appeals from his conviction for possession of a weapon by an inmate. ORS 166.275. Defendant represented himself until the sentencing phase of the trial court proceedings. Although defendant makes four assignments of error on appeal, we address only his contention that the trial court erred in accepting his purported waiver of counsel. Defendant asserts that the waiver was invalid under the Oregon and federal constitutions because the trial court did not advise him on the record of “any of the pitfalls” of self-representation. We affirm.

Under Article I, section 11, of the Oregon…