HRS 0802-0002 ANNOTATIONS

Failure to advise indigent pro se defendant of right to counsel and to have one appointed at cost to State reversible error. 80 H. 246 (App.), 909 P.2d 574.

No waiver by indigent defendant of right to counsel where trial court failed to conduct the necessary inquiry with defendant to ensure that defendant had knowingly and intelligently waived right to be represented by counsel at trial and to have one appointed if indigent. 80 H. 246 (App.), 909 P.2d 574.