State v. Lucke
State v. Lucke, 2025 UT App 49 (Tenney, J.)
Criminal Law
The Utah Court of Appeals held:
- The district court did not conduct an adequate Frampton colloquy.
- The record does not establish that Defendant knowingly and intelligently waived his right to counsel.
- Practice tip: The lack of a knowing and intelligent waiver of the right to counsel constitutes structural error, so there is no need to demonstrate prejudice.