MICHAEL EDWARD COX Missouri Cases

Michael Edward Cox appealed his misdemeanor convictions and an infraction, arguing the trial court erred by allowing him to represent himself without a valid waiver of counsel. Cox contended his written waiver did not comply with statutory requirements and the waiver hearing was not on the record. The Southern District of the Missouri Court of Appeals reversed Cox's misdemeanor convictions and remanded the case, finding plain error in the trial court's failure to ensure a knowing and intelligent waiver of counsel. However, the court affirmed the judgment as to the infraction, noting the right to counsel does not extend to such offenses.