Patton v. Mississippi
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Pro se prisoner Edgar Earl Patton appealed his convictions on false pretense and fraudulent use of identity. He argued: (1) the circuit court judge engaged in improper ex parte communications; (2) he was denied his Sixth-Amendment right to counsel at all critical phases; (3) the circuit court erred in denying his motion to recuse the trial judge; (4) the circuit court erred by allowing a substantive amendment to the indictment; (5) he was denied the right to compulsory service of process; (6) Patton’s Fourth-Amendment protection against unlawful search and seizure was violated; (7) the circuit court erred by violating Uniform Circuit and County Court Rule 1.11; (8) the circuit court judge’s inquiry into Patton’s educational background for purposes of determining his ability to represent himself was an improper discovery tool that benefitted the State and violated his Fifth-Amendment right against self-incrimination; (9) the circuit court erred by denying Patton’s motion for directed verdict; (10) jurisdiction was improper and venue was not established; (11) the jury was improperly instructed; and (12) the indictment was legally insufficient and defective. Finding no reversible error, the Supreme Court affirmed Patton’s convictions and sentences.
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