Question of whether Plaintiff was denied his Sixth Amendment right to counsel.

Plaintiff was stopped while driving in City of Atalla. Vehicle had a homemade license instead of State issued tag. Plaintiff could not provide a driver’s license or proof of insurance. He only provided his first and middle names. He was charged with giving a false name to law-enforcement, driving without a driver’s license, driving a motor vehicle without a tag, and driving without insurance coverage. Plaintiff appealed.

The record did not show if the circuit court made inquiry into Plaintiff’s indigent status. There was no indication that the court advised Plaintiff of the dangers and disadvantages of self-representation. The Court stated the Plaintiff’s representation of himself in prior criminal matters, “is not sufficient evidence of his waiver of his right to counsel in the case now under review.”

Judgment reversed.