State v. Harvin
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The Supreme Court affirmed the decision of the court of appeals vacating the judgments entered upon Defendant's convictions for multiple serious felonies, including first-degree murder, holding that the record did not support the trial court's determination that Defendant's actions were sufficiently obstructive to constitute a forfeiture of his right to counsel.
Defendant was indicted on charges of first-degree murder, attempted first-degree murder, and other crimes. The trial court decided before trial that Defendant's actions forfeited his opportunity to have assigned counsel, and Defendant proceeded pro se. The jury returned guilty verdicts on all offenses, and Defendant was sentenced to life imprisonment for the murder conviction. The court of appeals awarded Defendant a new trial, determining that the trial court deprived Defendant of his constitutional right to counsel by concluding that he had forfeited that right. The Supreme Court affirmed, holding that Defendant was entitled to a new trial because he did not engage in the type of egregious misconduct that would permit the trial court to deprive him of his constitutional right to counsel.
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