Hill v. Curtin, No. 12-2528 (6th Cir. 2015)
Annotate this CaseOn the first day of Hill’s criminal trial, as potential jurors were on their way to the courtroom, Hill stated that he wanted to represent himself. The judge denied the request. A jury convicted Hill of armed robbery and carjacking. As a third-felony habitual offender, he was sentenced to concurrent terms of 20-40 years for each conviction. The Michigan Court of Appeals affirmed, finding that Hill’s self-representation request was not knowingly and intelligently made. The Michigan Supreme Court affirmed, holding that Hill’s right to self-representation was not violated because his request was untimely and disruptive. The U.S. Supreme Court denied certiorari. The district court denied Hill’s timely habeas corpus petition. The Sixth Circuit affirmed. Congress enacted the Antiterrorism and Effective Death Penalty Act to reduce delays and to further the principles of comity, finality, and federalism. The Michigan Supreme Court affirmed denial of defendant’s request as “not timely” because “granting the request at that moment would have disrupted, unduly inconvenienced, and burdened the administration of the court’s business.” A judge may fairly infer that a defendant’s last-minute decision to represent himself would cause delay. Under these circumstances, upholding of the trial court’s factual determination was debatable in light of the whole record and not unreasonable.
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.