Werth v. Bell, No. 10-2183 (6th Cir. 2012)
Annotate this Case
Werth was charged with robbing a convenience store. Before he pleaded guilty to breaking and entering with the intent to commit larceny and to possession of burglar’s tools, Werth attempted at least seven times to assert his Sixth Amendment right to self-representation.
The trial court denied his request summarily the first six times. The seventh time, the judge explained the nature of the charges against Werth, told him that she could not give him special training or treatment, and denied his request without giving him an opportunity to speak. Three weeks later, the judge denied Werth’s motion to withdraw his guilty plea, in which he argued duress. The Michigan Court of Appeals and the Michigan Supreme Court denied his application for leave to appeal. The district court denied Werth’s petition for habeas corpus. Applying AEDPA deference, it held that Werth waived his self-representation claim by pleading guilty. The Sixth Circuit affirmed. It did not violate clearly established Supreme Court precedent for the
Michigan appellate courts to conclude that Werth’s guilty plea foreclosed his challenge.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.