Jackson v. Bartow, No. 19-1168 (7th Cir. 2019)
Annotate this CaseJackson was charged with throwing boiling oil at his wife, knifing her in front of their children, and later, threatening her from prison. Jackson asked the judge to remove his appointed counsel. The court granted the motion and barred Jackson from communicating with anyone but his attorney of record because of his threatening phone calls. A second appointed lawyer reported that Jackson asked him to withdraw. The court ruled that Jackson’s reasons were inadequate and refused to appoint another lawyer but allowed Jackson to seek a private attorney in compliance with the restrictions on his outside communications. The court denied Jackson’s request to represent himself. Months later, the court returned to Jackson’s request. It stressed the complexity of the case and stated that Jackson “can’t do this.” The court denied Jackson’s request. Jackson pleaded guilty to felony intimidation of a witness, first-degree reckless injury, and aggravated battery and was sentenced to 20 years’ imprisonment. Jackson filed an unsuccessful post-conviction petition in Wisconsin, seeking to withdraw his guilty plea. In his federal habeas action, Jackson argued that, because he was competent to plead guilty, he was competent to represent himself at trial. The Seventh Circuit affirmed the denial of that petition. Although the Wisconsin appeals court unreasonably applied Supreme Court precedent on the Sixth Amendment right to self-representation at trial, Jackson waived the error by validly pleading guilty.
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