Benson v. State

Summary

The Court affirmed Benson’s violation-of-probation judgment and sentence. It held that Benson had no constitutional right to counsel at the hearing because he admitted the violation and his explanation was neither substantial nor complex, so the court was not required to conduct a waiver colloquy after he chose to proceed pro se. The Court also held that the sentencing judge did not act with a closed mind because the judge considered the circumstances of the violation and Benson’s mitigating medical evidence.