State v. BunyardAnnotate this Case
The Supreme Court reversed the decision of the Court of Appeals and the judgment of the district court convicting Defendant of battery and other offenses, holding that the trial court committed structural error in handling Defendant’s invocation of his right to self-representation.
At a motions hearing before Defendant’s trial was to begin, Defendant interjected during argument before the court and stated that he wanted it on the record that he was “unequivocally” asserting his right to self-representation. The judge refused to take up the matter of self-representation, telling Defendant that he must file a written motion if he wanted to represent himself. Defendant did not file the motion or otherwise reassert the right to self-representation when court reconvened. The Court of Appeals affirmed Defendant’s convictions and sentence, rejecting Defendant’s claim that he was denied his right to self-representation. The Supreme Court concluded that Defendant was denied his right to self-representation and that the error was structural. The court remanded the case to the district court for further proceedings.