State v. Rhoads
Annotate this CaseAppellant Denon Rhoads was initially charged with a single count of second-degree burglary. At a pretrial hearing, Rhoads asserted his right to self-representation and signed a written waiver of counsel. The State later amended the complaint to include a count of first-degree burglary that roughly doubled the maximum possible punishment. On the day of trial, Rhoads renewed his waiver-of-counsel. The district court, however, did not conduct an on-the-record inquiry of Rhoads's understanding of the maximum punishment that might be imposed if he were convicted of first-degree burglary. Rhoads was later convicted of first- and second-degree burglary. The Supreme Court reversed Rhoads's first-degree burglary conviction and remanded, holding that because the record did not support an inference that when Rhoads renewed his waiver-of-counsel he understood the maximum possible punishment he faced had doubled, the renewed waiver-of-counsel was not knowing and intelligent. Remanded.
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