Appellant was tried for capital murder. He asserted his right to represent himself, but was denied solely because it was a death penalty trial. Two new counsel were appointed over his objection. Here, the California Supreme Court reversed the judgment under compulsion of Faretta v. California (1975) 422 U.S. 806. Although the evidence against appellant was overwhelming, and the record shows he was adequately represented and received a fair trial, the trial court denied the self-representation request because of its misunderstanding of the law. Erroneous denial of a Faretta motion is reversible per se.
Case Summaries