The United States Supreme Court has held that absent a knowing and intelligent waiver, no person can suffer a "loss of liberty" regardless of the categorization of the criminal offense or the maximum imposable punishment unless he has been represented by counsel at his trial.
Argersinger v. Hamlin, 407 U.S. 25 (1972).
Robert B. Evanick,
Constitutional Law - Right to Appointed Counsel - Indigent Misdemeanant,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol12/iss1/17