Finch v. Payne, No. 19-2369 (8th Cir. 2020)
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The Eighth Circuit affirmed the district court's grant of plaintiff's 28 U.S.C. 2254 motion for habeas relief based on the denial of his Sixth Amendment right to self-representation. Defendant was convicted of aggravated residential burglary, aggravated assault on a family or household member, and first-degree terroristic threatening.
The court held that plaintiff clearly and unequivocally invoked his right to self-representation; as soon as he manifested this clear and unequivocal invocation, the proceedings should have paused, and the trial court should have conducted a proper Faretta hearing; and thus the Arkansas Supreme Court's finding to the contrary was an objectively unreasonable application of clearly established Federal law. The court also held that the record does not support a finding that plaintiff engaged in serious and obstructionist misconduct, and the Arkansas Supreme Court's finding to the contrary is objectively unreasonable. In this case, there is no evidence in the record that defendant was attempting to manipulate, subvert, or delay the trial process. Finally, the state waived its argument that there was a determination that plaintiff was incapable, under Faretta, of waiving his right to counsel.
Court Description: [Shepherd, Author. with Loken and Erickson, Circuit Judges] Prisoner case - Habeas. The court's review of the grant of habeas is limited to determining whether the Arkansas Supreme Court's disposition of Finch's case involved an objectively unreasonable application of clearly established Federal law; at his trial, Finch made a clear and conclusive invocation of his right to proceed pro se and the Arkansas Supreme Court's finding to the contrary was objectively unreasonable; there was no evidence in the record that Finch was attempting to manipulate, subvert or delay the trial process and the Arkansas Supreme Court's finding that his conduct would have prevented the fair and orderly exposition of the issues was objectively unreasonable; the State's argument that there was a determination that Finch was incapable, under Faretta, of waiving his right to counsel was not presented to the district court and would not be considered on appeal; the grant of habeas relief is affirmed.
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