Clark v. Lindsey, No. 18-1640 (6th Cir. 2019)
Annotate this CaseConvicted of criminal sexual assault and domestic violence, Clark argued that his convictions should be set aside based on a Sixth (and Fourteenth) Amendment violation that allegedly arose when a scheduling error prohibited his lawyers from being physically present at his competency hearing. The Michigan Court of Appeals rejected the claim on the ground that the attorneys nonetheless were able to communicate with Clark and the court about the competency report and all agreed that he no longer would challenge his competence. Clark filed an unsuccessful federal habeas petition. The Sixth Circuit affirmed the denial of relief. No U.S. Supreme Court case requires a different result. The state court reasonably denied Clark’s claim of structural error. According to the U.S. Supreme Court, a defendant can show a Sixth Amendment violation without the need to prove prejudice when there is a “complete denial of counsel” at, or counsel is “totally absent” from, a “critical stage of the proceedings.” The state did not prevent Clark’s attorneys from attending the hearing and the error was mitigated by the attorneys’ earlier communication with Clark and the judge about the competency report and earlier decision not to challenge his competence any longer.
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