State v. Lee, 542 P.3d 974

Timothy Lee was pulled over for speeding and charged with multiple offenses including failure to stop for police, drug possession, and driving with a suspended registration.
Initially denied a public defender for not qualifying financially, Lee hired private counsel, but then insisted on representing himself at arraignment due to dissatisfaction with his attorney.
The district court conducted only a superficial inquiry into Lee’s understanding of self-representation and allowed him to waive counsel, noting a need for further discussion that never meaningfully happened.
Lee represented himself at trial, did not demonstrate understanding of the legal process, and was convicted on all charges.
On appeal, Lee argued that his waiver of counsel was not made knowingly and intelligently.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Lee knowingly and intelligently waived right to counsel	Lee argues his waiver was not knowing/intelligent	State argues waiver was voluntary and valid	Lee’s waiver was not knowing/intelligent; convictions vacated.

State v. West, 532 P.3d 114 (Utah Ct. App. 2023) (sets standard for reviewing knowing and intelligent waiver and appellate review)
State v. Hassan, 108 P.3d 695 (Utah 2004) (trial court's duty to ensure voluntary, knowing, intelligent waivers)
State v. Frampton, 737 P.2d 183 (Utah 1987) (model colloquy for waivers; court must ascertain defendant's understanding of risks)
State v. Pedockie, 137 P.3d 716 (Utah 2006) (validity of waiver assessed at the time of waiver, not based on later conduct)