Mayfield v. Delaware
Annotate this CaseAppellant Kili Mayfield was convicted at a bench trial of Rape in the First Degree (two counts), Rape in the Second Degree (four counts), Kidnapping in the First Degree (one count), Strangulation (one count), and Assault in the Third Degree (one count). In pre-trial proceedings, he was initially represented by counsel from the Public Defender Division of the Office of Defense Services. Several months before trial Mayfield filed a motion indicating he wished to waive his right to counsel and proceed pro se. The Superior Court held a hearing and granted the motion. On appeal, Mayfield did not dispute that the Superior Court committed no error in granting his motion to waive counsel and proceed pro se. At a conference held the day before his scheduled trial date, however, Mayfield informed the trial judge for the first time that he had decided that representing himself was not in his best interest. He requested time to retain private counsel. In the alternative, he requested that the Public Defender’s Office be reappointed to represent him at trial. After fully considering Mayfield’s requests, the judge determined that granting either request would necessitate a trial delay. He also determined that the trial should go forward as scheduled the next day, that the continuance that either of Mayfield’s requests would entail should be denied, and that his request for counsel should, therefore, be denied. The trial did commence the next day, with Mayfield representing himself. Mayfield claimed on appeal the trial judge’s denial of his request for reappointment of the Public Defender’s Office to represent him at trial violated his Sixth Amendment right to assistance of counsel. Finding no reversible error, the Delaware Supreme Court rejected Mayfield’s claim and affirmed the Superior Court judgment.
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