Fullwood v. State, 290 Ga. 335

Fullwood pleaded guilty in 1988 to possession of cocaine with intent to distribute and received a ten-year probation sentence under the First Offender Act.
He was 20 years old and not represented by counsel at the guilty plea hearing.
The sentencing court did not inform him of the right to counsel at the plea hearing, though it advised rights at a jury trial.
Fullwood filed a habeas petition alleging denial of counsel, lack of waiver, and misunderstanding of self-representation.
The habeas court denied relief, finding a knowing and voluntary waiver based on a signed plea form and a generalized waiver of the right to counsel.
The Supreme Court reversed, holding the waiver could not be knowing and voluntary due to lack of proper informed waiver at the plea hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Fullwood validly waived counsel at the plea hearing.	Fullwood did not knowingly waive counsel.	Waiver was voluntary based on signatures and form language.	Waiver was not knowing or voluntary; reversal affirmed.

Jones v. Terry, 279 Ga. 623 (2005) (waiver of counsel requires knowing and voluntary informed waiver)
Iowa v. Tovar, 541 U.S. 77 (2004) (informs rights and range of punishments for valid waiver)
State v. Futch, 279 Ga. 300 (2005) (signature and general waiver insufficient for knowing waiver)