On Point blog, page 4 of 4
Counsel – Waiver; Plea-Withdrawal – Issuance of Worthless Check – Elements
State v. Kenneth B. Bonner, 2010AP1414-CR, District 1, 12/28/10
court of appeals decision (1-judge, not for publication); for Bonner: Dennis P. Coffey; case activity; Bonner BiC; State Resp.
Counsel – Waiver
The trial court’s waiver colloquy omitted two required components: assurance that the defendant made a deliberate choice to proceed without counsel, and was aware of the difficulties and dangers of self-representation,
Counsel – Waiver – Self-Representation
State v. Rashaad A. Imani, 2010 WI 66, reversing 2009 WI App 98;habeas relief granted 6/22/16; for Imani: Basil M. Loeb; BiC; Resp.; Reply
¶3 We conclude that the circuit court properly denied Imani’s motion to represent himself. First, we determine that Imani did not knowingly, intelligently, and voluntarily waive the right to counsel. The circuit court engaged Imani in two of the four lines of inquiry prescribed in Klessig and properly determined that Imani (1) did not make a deliberate choice to proceed without counsel,
Criminal Appeals, Duties of Counsel, Generally
State v. Iran D. Evans, 2004 WI 84, reversing unpublished decision of court of appeals
For Evans: Robert R. Henak
Issue/Holding:
¶30. During postconviction proceedings, a defendant must choose between being represented by the SPD, proceeding pro se, or securing private representation. State v. Redmond, 203 Wis. 2d 13, 19, 552 N.W.2d 115 (Ct. App. 1996). A defendant does not have the right to hybrid representation on appeal.