Batchelor v. Cain, No. 10-30802 (5th Cir. 2012)
Annotate this CaseMonths before his criminal trial, petitioner moved to dismiss his appointed counsel in exercise of his constitutional right to represent himself under Faretta v. California. The trial court denied the motion and petitioner was subsequently convicted. On direct appeal, a state appellate court reversed the conviction due to the denial of petitioner's right to self-representation, but the court then granted rehearing, and a five-judge panel affirmed petitioner's conviction and sentence. Petitioner subsequently filed a habeas corpus application in federal district court under 18 U.S.C. 2254, and the court granted relief. The court concluded that petitioner made a clear and unequivocal invocation of his Sixth Amendment right to represent himself and that the state trial court erroneously denied his request in violation of Faretta. The state court's implicit finding of waiver was unreasonable in light of the evidence presented in the state court proceeding. Therefore, the court affirmed the district court's grant of habeas relief.
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