State of Minnesota v. David John Young, A15-2057

David Young used another person’s credit card in June 2015; he pleaded guilty to felony financial transaction card fraud (other burglary charge dismissed).
Young was given a one-day furlough, failed to return, and was later charged with felony escape from custody; he was initially represented by counsel on the escape charge.
At a September 2015 hearing Young discharged his public defender and stated he would represent himself; the district court accepted that without conducting the Rule 5.04 inquiry or obtaining a written waiver.
Young later pleaded guilty to escape from custody (after initially rejecting, then accepting a plea offer) while unrepresented; he was sentenced to concurrent prison terms (17 months for card fraud, 22 months for escape).
On appeal Young challenged the validity of his waiver of counsel; the state filed no brief defending the waiver. The court reviewed the record and reversed and remanded both the escape conviction and the card-fraud sentence for failure to ensure a knowing, intelligent, and voluntary waiver.

Issue	Plaintiff's Argument (Young)	Defendant's Argument (State)	Held
Whether Young validly waived his Sixth Amendment/right-to-counsel before proceeding pro se	Waiver invalid because court failed to advise him of charges, punishments, defenses, and other consequences as required by Minn. R. Crim. P. 5.04	(State did not defend on appeal)	Court held the district court failed to obtain a valid waiver and reversed the escape conviction and resentencing for card fraud
Whether the Rule 5.04 defect was harmless because counsel previously represented Young	Counsel’s prior representation did not establish he was advised of risks specific to proceeding unrepresented on the escape charge and related sentencing consequences	(State offered no contrary record showing counsel advised Young of those risks)	Court refused to presume a valid waiver from prior counsel involvement and found reversal required

State v. Worthy, 583 N.W.2d 270 (Minn. 1998) (standard for reviewing waiver of counsel; prior discussions with counsel can bear on waiver)
State v. Rhoads, 813 N.W.2d 880 (Minn. 2012) (courts may uphold imperfect on-the-record waivers when the record otherwise shows a valid waiver)
State v. Krejci, 458 N.W.2d 407 (Minn. 1990) (valid waiver inferred where defendant was experienced, advised of charges/punishment, and engaged with counsel)
State v. Garibaldi, 726 N.W.2d 823 (Minn. App. 2007) (reversal where record did not support a finding that waiver was valid and defendant lacked opportunity to consult counsel)
State v. Camacho, 561 N.W.2d 160 (Minn. 1997) (trial court must ensure waiver is knowing and voluntary)
Gardner v. Florida, 430 U.S. 349 (1977) (right to counsel applies to critical stages including sentencing)