Ronald Stewart represented himself at trial and was convicted of aggravated battery, felony obstruction, and simple battery. The Court of Appeals of Georgia held that the evidence was sufficient but that the trial court had not established a knowing and voluntary waiver of Stewart’s constitutional right to counsel. Stewart had retained and lost several attorneys and had consistently said he would obtain counsel, yet the court did not conduct the required Faretta inquiry or explain the dangers of self-representation. Because the waiver error was not harmless, the court reversed and remanded for a new trial, while recognizing that the State could retry Stewart because the evidence was sufficient.