”Waiver of Attorney” Form Example

In Strozier v. State, 187 Ga. App. 16, 17 (1) (369 S.E.2d 504) (1988), the Court held that a trial court erred when it failed to make a determination on the record that the defendant in a criminal trespass case had voluntarily and knowingly chosen to proceed pro se.

In Strozier, we found the trial court erred by not making the required determination, even though the defendant signed a "waiver of counsel" form that stated:

I, the undersigned, defendant in the above stated matter, having been fully acquainted with my right to counsel, fully understand my rights involved, do desire not to be represented by counsel and do hereby waive my right to counsel fully and completely in these proceedings. Id. at 16.