Cameron Faulkner represented himself at trial after a traffic stop and vehicle search led to charges involving a stolen firearm, an altered firearm mark, marijuana, and firearm possession by a felon. On appeal, he argued that the trial court improperly approved his self-representation without ensuring that his waiver of counsel was knowing and intelligent. The Georgia Court of Appeals held that the record did not show the required inquiry into the dangers and disadvantages of proceeding without counsel. Because the State did not establish that the constitutional error was harmless, the court reversed and remanded for the trial court to ask whether Faulkner wanted counsel and then retry the case under his election. The court found the evidence sufficient for retrial and therefore did not reach Faulkner’s separate challenge to the timing of his suppression motion.