Cox v. State (2012)

This case, then, is inapt to the facts and circumstances presented in Rivera, and the trial court here did not abuse its discretion in finding Freeman’s waiver of counsel to be knowing and voluntary.17 17 See State v. Evans, 285 Ga. 67, 69 ( 673 SE2d 243 ) (2009) (explaining that “a defendant’s waiver of his right to counsel is valid if the record reflects that the defendant was made aware of the dangers of self-representation and nevertheless made a knowing and intelligent …

A “trial court’s ruling as to whether the defendant’s waiver of the right to counsel was valid is reviewed for abuse of discretion.” Cox v. State, 317 Ga. App. 654, 654 ( 732 SE2d 321 ) (2012) (footnote omitted).

“The state has the burden of demonstrating that the defendant received sufficient information and guidance from the trial court to make a knowing and intelligent waiver of the right to counsel.” (Citations, punctuation and footnote omitted.) Cox v. State, 317 Ga. App. 654, 655 ( 732 SE2d 321 ) (2012).

“The state has the burden of demonstrating that the defendant received sufficient information and guidance from the trial court to make a knowing and intelligent waiver of the right to counsel.” (Citations, punctuation and footnote omitted.) Cox v. State, 317 Ga. App. 654, 655 ( 732 SE2d 321 ) (2012). 4 The record shows that McDaniel was arrested in September 2010 on charges relating to mortgage fraud and remained in jail following his arrest.

See Cox , 317 Ga. App. at 655 , 732 S.E.2d 321 ("The state has the burden of demonstrating that the defendant received sufficient information and guidance from the trial court to make a knowing and intelligent waiver of the right to counsel." (footnote omitted)).