People v. Pizzaro (1990)

See Munoz v. Keane, 777 F.Supp. 282, 285 (S.D.N.Y.1991) (concluding that a prosecution conducted by an unlicensed attorney does not violate a defendant's right to fair procedure or deprive him of constitutional safeguards guaranteed under the Due Process Clause); Dunson, 250 Ill.Dec. 77 , 737 N.E.2d at 706 (relying on common law, not due process, to hold a trial null and void where a non-licensed attorney participated); Anderson v. State, 699 N.E.2d 257, 259 (Ind.1998) (requ…

See, Anderson v. State, 699 N.E.2d 257, 259-60 (Ind.1998)(finding that de facto officer doctrine validated an unlicensed prosecutor’s actions, because the defendant failed to demonstrate prejudice from the prosecutor’s involvement); State v. Escalante, 458 N.W.2d 787, 790-91 (S.D.1990) (applying the de facto officer doctrine where the prosecuting attorney signed the charging documents a few days prior to the issuance of his law license); People v. Pizzaro, 146 Misc.2d 527 , …