☢ test - Í

Shabazz v. State, 259 Ga.App. 339, 341(2) (577 S.E.2d 45) (2003), we warned against mass plea hearings involving general plea-related questions asked of the defendants as a group, we did not find mass plea hearings impermissible per se. In fact, mass plea hearings are not improper so long as defendants are informed of their constitutional rights, and are individually advised regarding the charges against each as well as the possible sentences. See Isaac v. State, 237 Ga.App. 723, 726(2) (516 S.E.2d 575) (1999). Here, ... the trial court informed all defendants collectively of their constitutional rights but also questioned each defendant, including Lamb, individually as to whether she could read and write, whether she understood her constitutional rights, and whether she had conferred with counsel. In addition, the court discussed with Lamb individually the charges against her, possible sentences, and the fact that her previous conviction for possession could affect the sentence. Under these circumstances, the trial court was authorized to conclude that Lamb’s guilty plea was voluntarily, knowingly, and intelligently made and was supported by a sufficient factual basis. See id. Consequently, the mass guilty plea hearing was not improper .” See Shabazz (January 29, 2003), below, for a cautionary note on mass guilty pleas. Iowa v. Tovar, 541 U.S. 77, 124 S.Ct. 1379, 158 L.Ed.2d 209 (March 8, 2004). Reverses Iowa Supreme Court’s holding that the Sixth Amendment requires that a pro se defendant be given the following warnings before pleading guilty: “The trial judge [must] advise the defendant generally that there are defenses to criminal charges that may not be known by laypersons and that the danger in waiving the assistance of counsel in deciding whether to plead guilty is the risk that a viable defense will be overlooked;” and “[t]he defendant should be admonished that by waiving his right to an attorney he will lose the opportunity to obtain an independent opinion on whether, under the facts and applicable law, it is wise to plead guilty.” “In prescribing scripted admonitions and holding them necessary in every guilty plea instance … the Iowa high court overlooked our observations that the information a defendant must have to waive counsel intelligently will ‘depend, in each case, upon the particular facts and circumstances surrounding that case,’ [cit.]” This case, a DUI (“OWI”), is “so straightforward” that “the admonitions at issue might confuse or mislead a defendant more than they would inform him,” by causing him to pursue non-existent defenses, wasting either his own resources or the State’s. “The constitutional requirement is satisfied when the trial court informs the accused of the nature of the charges against him, of his right to be counseled regarding his plea, and of the range of allowable punishments attendant upon the entry of a guilty plea.” Note, this was a “mass arraignment.” Shabazz v. State, 259 Ga.App. 339, 577 S.E.2d 45 (January 29, 2003). “While a mass guilty plea hearing is not impermissible, the procedure followed in this case would appear ripe for error, especially in those cases involving felony offenses where, as here, lengthy sentences can be imposed. In this case, general, plea-related questions were asked of the defendants as a group and answers were given as a group by each defendant in seriatim; the prosecutor related, one after another, the fact bases for the all of the defendants’ pleas; and none of the defendants were individually questioned about waiver-related issues. Clearly, serial answers by multiple defendants to general court imposed questions make it difficult to ascertain the veracity of the answers given by any individual defendant so as to fulfill the trial court’s obligation to determine whether trial rights are knowingly and voluntarily waived. Further, serial factual scenarios in support of numerous counts of numerous indictments involving numerous defendants leave, as in this case, little room for evidentiary development and exacerbate the difficulty in keeping track of which offenses belong to what defendant under which indictment. We recommend a close examination of such procedure in light of the requirements of Uniform Superior Court Rules 33.7 through 33.9, and 33.11.” Overruled on other grounds, Adams v. State, 285 Ga. 744, 683 S.E.2d 586 (September 28, 2009). Isaac v. State, 237 Ga.App. 723, 516 S.E.2d 575 (April 22, 1999). Defendant’s guilty plea was entered freely and voluntarily, despite fact that “Isaac was one of fourteen defendants who pled guilty to various crimes at the hearing.” Defendant was represented by counsel. “In conducting the hearing, the trial court first addressed certain questions to the defendants as a group, and the defendants’ answers to these questions were individually recorded by the court reporter. In response to these questions, Isaac indicated, among other things, that he was not under the influence of any substance; that he could read, write, and understand the English language; that he had read and understood the indictment; and that he was completely satisfied with his attorney’s representation. The judge then advised the defendants as a group of their constitutional rights, including the right to a jury trial; the right to subpoena and confront witnesses; the right to testify on their own behalf and offer other evidence; and the right to have the assistance of a lawyer.” Trial court reviewed facts of each case with individual defendants. Held, defendant’s plea was not entered at an improper “mass arraignment.” “In several cases, we have indicated that ‘[i]t is difficult to imagine a mass arraignment procedure which could satisfy the trial court’s burden of establishing that a proper waiver of counsel has occurred.’ (Emphasis supplied.) Jones v. State, 212 Ga.App. 676, 679(1), 442 S.E.2d 908 (1994); see also Washington v. City of Atlanta, 201 Ga.App. 876, 412 S.E.2d 624 (1991); Turner v. State, 162 Ga.App. 806(1), 293 S.E.2d 67 (1982). However, these cases ‘do not hold that a “mass