Huggins v. Texas (original by judge keel)
Annotate this CaseAppellant Noel Huggins pled pro se guilty to possession of methamphetamine and was sentenced by the trial court to 18 years in prison. The Texas Court of Criminal Appeal granted review to decide whether his right to counsel was violated. Appellant’s state-jail, possession charge was enhanced with two prior felonies. Appellant doubted the validity of the enhancement allegations, and that doubt helped fuel his on-again/off-again self-representation. He represented himself at the beginning and the end of his case, but he was otherwise represented by two attorneys appointed in succession during most of the approximately 22 months that his case was pending in the trial court. After his trial date was reached during his second period of self- representation and while a venire was standing by, he announced that he would plead guilty and asked for representation again, but the trial court refused to appoint a third attorney. Appellant argued that his two waivers of counsel were not made knowingly and intelligently because the trial court did not admonish him about the dangers and disadvantages of self-representation, and the trial court denied him his statutory right to withdraw his waiver of the right to counsel under Code of Criminal Procedure Article 1.051(h). The court of appeals said the trial court was not required to admonish Appellant of the dangers and disadvantages of self-representation because he did not contest his guilt. The court then looked at whether Appellant’s waiver of counsel was intelligent, knowing, and voluntary. Based on the totality of the circumstances, the court of appeals concluded that it was. The Texas Court of Criminal Appeals concluded Appellant's right to counsel was not violated.
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