Rhodes v. Dittmann, No. 14-1741 (7th Cir. 2015)
Annotate this CaseRhodes was charged with two counts of kidnapping. He retained Kovac. A jury acquitted him on one count; a different jury convicted him on the other. Rhodes appealed, claiming that Kovac had rendered ineffective assistance. The case was remanded, based on a problem with the jury. The court appointed a public defender, Kaiser. About two months before the trial was to begin, Kaiser moved to end his appointment. Rhodes wanted to represent himself. The court held a hearing and warned Rhodes, at length, about the dangers of self-representation. Kovac , who was present, said that he believed Rhodes was not engaging in gamesmanship or building a record for appeal, but that Rhodes had not retained him. After receiving a waiver, the judge granted Rhodes’s request. During the weeks that followed, there were several requests for additional time. It was not clear whether Kovac was representing Rhodes. The judge eventually told Rhodes he could not “have it both ways,” refused to grant an adjournment, and denied motions for standby counsel. The jury convicted Rhodes of kidnapping and aggravated battery. Wisconsin courts rejected his appeal. The federal district court granted habeas relief. The Seventh Circuit reversed. Neither of the state courts’ reasons for rejecting Rhodes’s last-minute request for counsel was unreasonable.
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