this hearing. At the conclusion of the hearing, the trial court sentenced Jackson to ninety days imprisonment. The record is completely devoid of any statements by the trial court informing Jackson of her right to counsel. Additionally, the record does not reveal the trial court warned Jackson in any way as to the dangers of self-representation. Moreover, the trial court did not determine, as required, that Jackson knowingly and intelligently waived the right to counsel. Our examination of the record does not reveal Jackson had a sufficient background or was apprised of her constitutional right to counsel by another source. Consequently, the trial court’s decision to sentence Jackson to ninety days imprisonment was reversible error. Thompson, 355 S.C. at 262-63, 584 S.E.2d at 134-35. (<HOLDING>). We note that this opinion is limited to the
holding that it is per se reversible error to prohibit adverse inference questioning of the venire holding the erroneous deprivation of the right to counsel constitutes per se reversible error holding that sua sponte grant of summary judgment without notice to the parties constitutes reversible error holding that constructive amendments which are per se reversible under harmless error analysis are also per se reversible under plain error analysis holding that the failure to hold a faretta hearing is per se reversible error and reversing the defendants conviction vacating his death sentence and remanding for a new trial