intelligent and competent waiver (Indiana) · Go Syfert
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intelligent and competent waiver in Indiana

14 Indiana opinions name it 2 courts 1951–2019 0 in the last five years

The cases below were cited by Indiana courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (5)

CaseFollowedCited
Eaton v. Stategreen
indctapp · 2008 · cited in 3 Indiana opinions naming this issue, 2018–2019
2 sentences

2019“Waiver of assistance of counsel may be established based upon the particular facts and circumstances surrounding the case, including the background, experience, and conduct of the accused.” Id. [17] “It is well established that there is a strong presumption against the waiver of the right to counsel, and it is the trial court that bears the ‘serious and weighty responsibility to determine whether there was an intelligent and competent waiver.’” Wirthlin v. State, 99 N.E.3d 699, 704 (Ind. Ct. App. 2018) (quoting Eaton v. State, 894 N.E.2d 213, 217 (Ind. Ct. App. 2008)) (emphasis supplied), tra

2019“Waiver of assistance of counsel may be established based upon the particular facts and circumstances surrounding the case, including the background, experience, and conduct of the accused.” Id. [12] “It is well established that there is a strong presumption against the waiver of the right to counsel, and it is the trial court that bears the ‘serious and weighty responsibility to determine whether there was an intelligent and competent waiver.’” Wirthlin v. State, 99 N.E.3d 699, 704 (Ind. Ct. App. 2018) (quoting Eaton v. State, 894 N.E.2d 213, 217 (Ind. Ct. App. 2008)) (emphasis supplied), tra

23
Stephen Wirthlin v. State of Indianagreen
indctapp · 2018 · cited in 2 Indiana opinions naming this issue, 2019–2019
2 sentences

2019“Waiver of assistance of counsel may be established based upon the particular facts and circumstances surrounding the case, including the background, experience, and conduct of the accused.” Id. [12] “It is well established that there is a strong presumption against the waiver of the right to counsel, and it is the trial court that bears the ‘serious and weighty responsibility to determine whether there was an intelligent and competent waiver.’” Wirthlin v. State, 99 N.E.3d 699, 704 (Ind. Ct. App. 2018) (quoting Eaton v. State, 894 N.E.2d 213, 217 (Ind. Ct. App. 2008)) (emphasis supplied), tra

2019“Waiver of assistance of counsel may be established based upon the particular facts and circumstances surrounding the case, including the background, experience, and conduct of the accused.” Id. [12] “It is well established that there is a strong presumption against the waiver of the right to counsel, and it is the trial court that bears the ‘serious and weighty responsibility to determine whether there was an intelligent and competent waiver.’” Wirthlin v. State, 99 N.E.3d 699, 704 (Ind. Ct. App. 2018) (quoting Eaton v. State, 894 N.E.2d 213, 217 (Ind. Ct. App. 2008)) (emphasis supplied), tra

22
Faretta v. Californiagreen
scotus · 1975 · cited in 2 Indiana opinions naming this issue, 2001–2019
2 sentences

2019The Court elaborated on the determination of a valid waiver stating that if a defendant chooses to forego the assistance of counsel and to represent herself, "[s]he should be made aware of the dangers and disadvantages of self-representation, so that the record will establish that [s]he knows what [s]he is doing and h[er] choice is made with eyes open." Faretta , 422 U.S. at 835 , 95 S.Ct. at 2541 , 45 L.Ed.2d at 581-82 (internal quotes omitted). [13] Our Supreme Court has adopted four factors for a trial court to consider when determining whether a knowing, voluntary and intelligent waiver ha

2019The Court elaborated on the determination of a valid waiver stating that if a defendant chooses to forego the assistance of counsel and to represent herself, "[s]he should be made aware of the dangers and disadvantages of self-representation, so that the record will establish that [s]he knows what [s]he is doing and h[er] choice is made with eyes open." Faretta , 422 U.S. at 835 , 95 S.Ct. at 2541 , 45 L.Ed.2d at 581-82 (internal quotes omitted). [13] Our Supreme Court has adopted four factors for a trial court to consider when determining whether a knowing, voluntary and intelligent waiver ha

22
Poynter v. Stategreen
ind · 2001 · cited in 2 Indiana opinions naming this issue, 2019–2019
2 sentences

2019“Waiver of assistance of counsel may be established based upon the particular facts and circumstances surrounding the case, including the background, experience, and conduct of the accused.” Id. [17] “It is well established that there is a strong presumption against the waiver of the right to counsel, and it is the trial court that bears the ‘serious and weighty responsibility to determine whether there was an intelligent and competent waiver.’” Wirthlin v. State, 99 N.E.3d 699, 704 (Ind. Ct. App. 2018) (quoting Eaton v. State, 894 N.E.2d 213, 217 (Ind. Ct. App. 2008)) (emphasis supplied), tra

2019“Waiver of assistance of counsel may be established based upon the particular facts and circumstances surrounding the case, including the background, experience, and conduct of the accused.” Id. [12] “It is well established that there is a strong presumption against the waiver of the right to counsel, and it is the trial court that bears the ‘serious and weighty responsibility to determine whether there was an intelligent and competent waiver.’” Wirthlin v. State, 99 N.E.3d 699, 704 (Ind. Ct. App. 2018) (quoting Eaton v. State, 894 N.E.2d 213, 217 (Ind. Ct. App. 2008)) (emphasis supplied), tra

22
Morgan v. Stategreen
indctapp · 1981 · cited in 1 Indiana opinions naming this issue, 1988–1988
2 sentences

1988In a criminal proceeding, we impose "the serious and weighty responsibility upon the trial judge of determining whether there is an intelligent and competent waiver [of the right to counsel] by the accused." Johnson v. Zerbst (1938), 304 U.S. 458, 465 , 58 S.Ct. 1019, 1023 , 82 L.Ed. 1461 ; see also Morgan v. State (1981), Ind.App., 417 N.E.2d 1154 .

1988In a *455 criminal proceeding, we impose "the serious and weighty responsibility upon the trial judge of determining whether there is an intelligent and competent waiver [of the right to counsel] by the accused." Johnson v. Zerbst (1938), 304 U.S. 458, 465 , 58 S.Ct. 1019, 1023 , 82 L.Ed. 1461 ; see also Morgan v. State (1981), Ind. App., 417 N.E.2d 1154 .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Indiana. Read the followed side critically anyway.

Also cited on this issue (9)

CaseCitedYears
Johnson v. Zerbst green
scotus · 1938
2 sentences

2019The Court went on to find that it is the responsibility of the trial judge to determine whether there is an intelligent and competent waiver and that it would be "fitting and appropriate for that determination to appear on the record." Id. at 465 , 58 S.Ct. at 1023 , 82 L.Ed. at 1467 .

2019The Court went on to find that it is the responsibility of the trial judge to determine whether there is an intelligent and competent waiver and that it would be "fitting and appropriate for that determination to appear on the record." Id. at 465 , 58 S.Ct. at 1023 , 82 L.Ed. at 1467 .

101970–2019
Jones v. State green
ind · 2003
2 sentences

2019“Waiver of assistance of counsel may be established based upon the particular facts and circumstances surrounding the case, including the background, experience, and conduct of the accused.” Id. [17] “It is well established that there is a strong presumption against the waiver of the right to counsel, and it is the trial court that bears the ‘serious and weighty responsibility to determine whether there was an intelligent and competent waiver.’” Wirthlin v. State, 99 N.E.3d 699, 704 (Ind. Ct. App. 2018) (quoting Eaton v. State, 894 N.E.2d 213, 217 (Ind. Ct. App. 2008)) (emphasis supplied), tra

2019“Waiver of assistance of counsel may be established based upon the particular facts and circumstances surrounding the case, including the background, experience, and conduct of the accused.” Id. [12] “It is well established that there is a strong presumption against the waiver of the right to counsel, and it is the trial court that bears the ‘serious and weighty responsibility to determine whether there was an intelligent and competent waiver.’” Wirthlin v. State, 99 N.E.3d 699, 704 (Ind. Ct. App. 2018) (quoting Eaton v. State, 894 N.E.2d 213, 217 (Ind. Ct. App. 2008)) (emphasis supplied), tra

22019–2019
Mitchell v. State green
indctapp · 1981
1 sentence

2018To discharge the duty imposed, a judge must investigate as long and as thoroughly as the circumstances of the case before him demand.' " Eaton v. State , 894 N.E.2d 213 , 217 (Ind. Ct. App. 2008) (quoting Mitchell v. State , 417 N.E.2d 364 , 369 (Ind. Ct. App. 1981) (internal citations omitted) ).

12018–2018
Jackson v. State green
ind · 2007
1 sentence

2013In Jackson , we pointed out that “a defendant’s absence from trial does not constitute a waiver of the right to counsel in every case.” Jackson, 868 N.E.2d at 499 .

12013–2013
Wallace v. State green
indctapp · 1977
2 sentences

1988Not only must an accused be aware of the nature, extent and importance of the right to counsel, but the accused must be made aware of the dangers and disadvantages of self-representation and the possible consequences thereof so "his choice is made with his eyes open." Wallace v. State (1977), 172 Ind.App. 535 , 361 N.E.2d 159, 164 , trans. denied.

1988Not only must an accused be aware of the nature, extent and importance of the right to counsel, but the accused must be made aware of the dangers and disadvantages of self-representation and the possible consequences thereof so "his choice is made with his eyes open." Wallace v. State (1977), 172 Ind.App. 535 , 361 N.E.2d 159, 164 , trans. denied.

11988–1988
Grubbs v. State green
ind · 1970
2 sentences

1979While an accused may waive the right to counsel, whether there is a proper waiver should be clearly determined by the trial court, and it would be fitting and appropriate for that determination to appear upon the record.’ 304 U.S. at 465 , 58 S.Ct. at 1023 .” 255 Ind. at 418 , 265 N.E.2d at 44 .

1979While an accused may waive the right to counsel, whether there is a proper waiver should be clearly determined by the trial court, and it would be fitting and appropriate for that determination to appear upon the record.’ 304 U.S. at 465 , 58 S.Ct. at 1023 .” 255 Ind. at 418 , 265 N.E.2d at 44 .

11979–1979
Grimes v. State green
ind · 1972
2 sentences

1972While an accused may waive the right to counsel, whether there is a proper waiver should be clearly determined by the trial court, and it would be fitting and appropriate for that determination to appear upon the record.’ 304 U.S. at 465 , 58 S. Ct. at 1023 .” In the case of Grimes v. State (1972), 257 Ind. 660 , 278 N. E. 2d 271 , in an opinion by Justice DeBruler, the question of a defendant’s right to assistance of counsel during arraignment leaves nothing to the imagination.

1972While an accused may waive the right to counsel, whether there is a proper waiver should be clearly determined by the trial court, and it would be fitting and appropriate for that determination to appear upon the record.’ 304 U.S. at 465 , 58 S. Ct. at 1023 .” In the case of Grimes v. State (1972), 257 Ind. 660 , 278 N. E. 2d 271 , in an opinion by Justice DeBruler, the question of a defendant’s right to assistance of counsel during arraignment leaves nothing to the imagination.

11972–1972
Batchelor v. State green
ind · 1920
1 sentence

1951While an accused may waive the right to counsel, whether there is a proper waiver should be clearly determined by the trial court, and it would be fitting and appropriate for that determination to appear upon the record.” See Batchelor v. State (1920), 189 Ind. 69 , 125 N. E. 773 .

11951–1951
Trkulja v. State green
ind · 1920
1 sentence

1951While an accused may waive the right to counsel, whether there is a proper waiver should be clearly determined by the trial court, and it would be fitting and appropriate for that determination to appear upon the record.” See Batchelor v. State (1920), 189 Ind. 69 , 125 N. E. 773 .

11951–1951

Where else courts name it

CA 22 (1946–2017) OH 20 (1976–2022) AL 17 (1987–2025) TN 15 (1972–2025) GA 15 (1986–2007) IN 14 (1951–2019) MS 12 (1964–2014) CT 9 (1976–2025) NJ 8 (1959–2018) MD 8 (1977–2013) AZ 8 (1968–2021) CO 7 (1984–2016) MI 6 (1962–2020) WI 6 (1959–2017) NY 5 (1975–2024) SC 5 (1977–2002) UT 4 (1988–2011) NM 4 (1986–2020) ID 3 (1967–2025) HI 3 (1992–2006) LA 3 (1975–2012) PA 3 (1980–2023) MA 2 (1976–1984) DC 2 (1974–1991) IA 2 (1943–2025) WA 2 (1968–1988)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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