Juvenile officer subsequently filed an amended petition, removing one of the assault charges. The court entered its finding of jurisdiction and order of disposition, and juvenile was placed on probation. Specifically, juvenile officer alleged that juvenile threw a rock at a youth just three days after he was placed on probation, and punched another youth in the head with a closed fist. Prior to the hearing on the motion to modify, juvenile and mother signed another waiver of counsel form and proceeded pro se. At the conclusion of the hearing, the court found juvenile had violated the terms of his probation and committed him to the Division of Youth Services for an indeterminate period of time.
Juvenile now appeals.
Juvenile proceedings are in the nature of civil proceedings, and the standard of review is the same as in a court-tried case. The trial court's order will be affirmed unless there is no substantial evidence to support it, it is against the weight of the evidence, or it erroneously declares or applies the law. In his first point, juvenile contends the trial court erred in failing to ensure his waiver of counsel was knowing and intelligent. Because this allegation of error was not properly preserved, we review only for plain error. Under plain error review, we will grant relief only if the trial court's action resulted in manifest injustice or a miscarriage of justice.