pro se defense (Alabama) · Go Syfert
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pro se defense in Alabama

11 Alabama opinions name it 2 courts 1987–2018 0 in the last five years

The cases below were cited by Alabama 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 (3)

CaseFollowedCited
Peter R. Fitzpatrick v. Louie L. Wainwrightgreen
ca11 · 1986 · cited in 9 Alabama opinions naming this issue, 1991–2018
2 sentences

2018The ultimate test is not the trial court's express advice but rather the defendant's understanding." Fitzpatrick v. Wainwright , 800 F.2d 1057 (11th Cir. 1986) (citations omitted).

2018The ultimate test is not the trial court's express advice but rather the defendant's understanding." Fitzpatrick v. Wainwright , 800 F.2d 1057 (11th Cir. 1986) (citations omitted).

19
Tomlin v. Stategreen
ala · 1991 · cited in 1 Alabama opinions naming this issue, 2008–2008
1 sentence

2008The ultimate test is not the trial court’s express advice but rather the defendant’s understanding.” ’ Tomlin v. State, 601 So.2d 124, 128 (Ala.1991) (quoting Fitzpatrick v. Wainwright, 800 F.2d 1057, 1065 (11th Cir.1986)). “ ‘Whether a defendant who chooses to represent himself has knowingly, intelligently, and voluntarily waived his right to counsel can be indicated by the record or by the totality of the circumstances surrounding the waiver.’ ” 3 Baker v. State, 933 So.2d 406, 409 (Ala.Crim.App.2005) (quoting Coughlin, 842 So.2d at 35 , citing Johnson, 304 U.S. at 464 , 58 S.Ct. 1019 ).

11
Baker v. Stategreen
alacrimapp · 2005 · cited in 1 Alabama opinions naming this issue, 2008–2008
1 sentence

2008The ultimate test is not the trial court’s express advice but rather the defendant’s understanding.” ’ Tomlin v. State, 601 So.2d 124, 128 (Ala.1991) (quoting Fitzpatrick v. Wainwright, 800 F.2d 1057, 1065 (11th Cir.1986)). “ ‘Whether a defendant who chooses to represent himself has knowingly, intelligently, and voluntarily waived his right to counsel can be indicated by the record or by the totality of the circumstances surrounding the waiver.’ ” 3 Baker v. State, 933 So.2d 406, 409 (Ala.Crim.App.2005) (quoting Coughlin, 842 So.2d at 35 , citing Johnson, 304 U.S. at 464 , 58 S.Ct. 1019 ).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (4)

CaseCitedYears
McKaskle v. Wiggins green
scotus · 1984
2 sentences

1987In McKaskle v. Wiggins, 465 U.S. 168 , 104 S.Ct. 944 , 79 L.Ed.2d 122 (1984), the U.S. Supreme Court, in affirming the defendant's conviction, held that while in that case counsel’s interference in the defendant’s pro se defense was not great enough to threaten his Faretta rights, if it had been, reversal would have been required.

1987In McKaskle v. Wiggins, 465 U.S. 168 , 104 S.Ct. 944 , 79 L.Ed.2d 122 (1984), the U.S. Supreme Court, in affirming the defendant's conviction, held that while in that case counsel’s interference in the defendant’s pro se defense was not great enough to threaten his Faretta rights, if it had been, reversal would have been required.

21987–1987
Faretta v. California green
scotus · 1975
1 sentence

2014Regardless of the mandatory language of Rule 6.1, “the Supreme Court[, in Faretta v. California, 422 U.S. 806 (1975),] does not require a specific colloquy between the trial judge and the defendant. ‘The case law reflects that, while a waiver hearing expressly addressing the disadvantage of a pro se defense is much to be preferred, it is not absolutely necessary.

12014–2014
Johnson v. Zerbst green
scotus · 1938
2 sentences

2008The ultimate test is not the trial court’s express advice but rather the defendant’s understanding.” ’ Tomlin v. State, 601 So.2d 124, 128 (Ala.1991) (quoting Fitzpatrick v. Wainwright, 800 F.2d 1057, 1065 (11th Cir.1986)). “ ‘Whether a defendant who chooses to represent himself has knowingly, intelligently, and voluntarily waived his right to counsel can be indicated by the record or by the totality of the circumstances surrounding the waiver.’ ” 3 Baker v. State, 933 So.2d 406, 409 (Ala.Crim.App.2005) (quoting Coughlin, 842 So.2d at 35 , citing Johnson, 304 U.S. at 464 , 58 S.Ct. 1019 ).

2008The ultimate test is not the trial court’s express advice but rather the defendant’s understanding.” ’ Tomlin v. State, 601 So.2d 124, 128 (Ala.1991) (quoting Fitzpatrick v. Wainwright, 800 F.2d 1057, 1065 (11th Cir.1986)). “ ‘Whether a defendant who chooses to represent himself has knowingly, intelligently, and voluntarily waived his right to counsel can be indicated by the record or by the totality of the circumstances surrounding the waiver.’ ” 3 Baker v. State, 933 So.2d 406, 409 (Ala.Crim.App.2005) (quoting Coughlin, 842 So.2d at 35 , citing Johnson, 304 U.S. at 464 , 58 S.Ct. 1019 ).

12008–2008
Coughlin v. State green
alacrimapp · 2002
1 sentence

2008The ultimate test is not the trial court’s express advice but rather the defendant’s understanding.” ’ Tomlin v. State, 601 So.2d 124, 128 (Ala.1991) (quoting Fitzpatrick v. Wainwright, 800 F.2d 1057, 1065 (11th Cir.1986)). “ ‘Whether a defendant who chooses to represent himself has knowingly, intelligently, and voluntarily waived his right to counsel can be indicated by the record or by the totality of the circumstances surrounding the waiver.’ ” 3 Baker v. State, 933 So.2d 406, 409 (Ala.Crim.App.2005) (quoting Coughlin, 842 So.2d at 35 , citing Johnson, 304 U.S. at 464 , 58 S.Ct. 1019 ).

12008–2008

Where else courts name it

IL 244 (1990–2026) FL 30 (1996–2022) SC 25 (1990–2026) NY 23 (1980–2021) WA 15 (1982–2025) TX 12 (1988–2016) AL 11 (1987–2018) PA 11 (1971–2024) MN 6 (1990–2018) IN 5 (2004–2024) CA 5 (1988–2016) MT 4 (1998–2014) VA 4 (1995–2024) CO 4 (2009–2019) GA 3 (2008–2023) NC 3 (1992–2004) MI 3 (1994–2015) MO 3 (1972–2016) LA 3 (1989–2008) MD 3 (1987–2010) AR 2 (2000–2001) WI 2 (1984–1992) OH 2 (1998–2020) IA 2 (2014–2026)

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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