State v. Houston

Summary

The Supreme Court of Georgia affirmed habeas relief vacating Houston's misdemeanor DUI convictions because he entered his guilty pleas without counsel and the trial court did not advise him that he had a right to counsel at the plea hearing. The court held that the plea forms did not establish a knowing and voluntary waiver of the right to counsel at the plea proceeding, and the habeas court did not clearly err in its factual findings. The court did not decide whether Houston functionally waived counsel by failing to secure representation.