Jean-Paul v. Douma, No. 14-3088 (7th Cir. 2015)
Annotate this CaseJean-Paul was convicted of state drug crimes and sentenced to 13 years’ confinement. His appointed appellate counsel, Donnelly, told Jean-Paul that he intended to file a “no-merit report,” unless Jean-Paul wanted to proceed pro se, in which case Donnelly would ask to withdraw. Jean-Paul wanted to proceed pro se. Donnelly wrote to Jean-Paul that if he signed a “Statement of Decision to Proceed Pro Se,” Donnelly would withdraw. Days later, Jean-Paul told Donnelly that instead of proceeding pro se, he wanted to respond to the No Merit report, which was due in May 2008. In April, Jean-Paul changed his mind. Donnelly withdrew and submitted Jean-Paul's signed “Statement of Decision to Proceed Pro Se.” Pro se, Jean-Paul voluntarily dismissed his appeal and brought an unsuccessful state post-conviction motion, which in Wisconsin precedes direct appeal. Jean-Paul refiled his direct appeal; the appellate court affirmed his conviction. The state appellate court rejected a habeas petition challenging the validity of his waiver of counsel on direct appeal. Jean-Paul claimed to be illiterate. Other petitions and appeals were unsuccessful. In federal court, Jean-Paul sought habeas relief, renewing his claim that he had not knowingly and intelligently waived his right to appellate counsel. The Seventh Circuit affirmed denial of relief, holding that the state court had applied the right standard and reached a reasonable result.
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