Missouri Court of Appeals, Southern District / Sep 20, 2024
STATE OF MISSOURI, Respondent v. CHRISTOPHER W. SMITH, Appellant
Christopher W. Smith was convicted of resisting arrest and unlawful use of a weapon after representing himself at trial. He appealed, arguing the trial court erred in finding he knowingly and intelligently waived counsel. The appellate court agreed, vacating the judgment and remanding for a new trial because Smith's written waiver of counsel failed to advise him of the maximum range of punishment as required by section 600.051, constituting plain error.