John-Charles v. State of California, No. 09-16530 (9th Cir. 2011)
Annotate this CaseDefendant appealed the denial of his federal habeas petition where his charges stemmed from a home-invasion robbery. At issue was the California Court of Appeals' rulings that he had no absolute Sixth Amendment right to the reappointment of counsel after waiving his right to counsel under Faretta v. California and whether the trial court's abuse of discretion in failing to reappoint counsel was harmless beyond a reasonable doubt. Also at issue was whether the California court violated his rights under Apprendi v. New Jersey when it used a prior juvenile conviction as a strike to enhance his sentence. The court held that because neither of these decisions "was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court," the district court's denial of defendant's habeas petition was affirmed.
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