Bryan v. State
The First DCA held the trial court reversibly erred by failing to renew the offer of counsel before hearing Bryan's pro se motion for new trial, a critical stage of the proceedings, requiring a new hearing on that motion. The court also held that the trial court illegally imposed consecutive habitual felony offender sentences for offenses committed during a single criminal episode, violating Hale v. State, and remanded for resentencing.
Key facts
- Bryan was convicted and sentenced to consecutive habitual felony offender-enhanced sentences for battery offenses arising from a single criminal episode.
- At the hearing on Bryan's motion for new trial, the trial court proceeded without renewing its offer of court-appointed counsel to the self-represented defendant.
- +2 more key facts with a free trial
Why it matters
This decision reinforces the strict procedural requirement that trial courts renew offers of counsel at every crucial stage for self-represented defendants, including hearings on new trial motions, and that failure to… — full analysis with a trial
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