competent waiver (Arizona) · Go Syfert
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competent waiver in Arizona

7 Arizona opinions name it 2 courts 1966–2023 3 in the last five years

The cases below were cited by Arizona 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 (4)

CaseFollowedCited
State v. Evansgreen
ariz · 1980 · cited in 2 Arizona opinions naming this issue, 2022–2023
2 sentences

2023See State v. Evans, 125 Ariz. 401, 403 (1980) (“In any determination of whether there has been a competent waiver of constitutional rights, the better practice would be for the trial judge to make specific findings, but if the record is adequate[,] the absence of specific findings is not reversible error.”). ¶20 Second, Johnson argues that § 13-4033(C) is unconstitutional because it is a procedural law that usurps this Court’s rulemaking authority.

2022In Glassel, although the defendant’s “condition worsened after the original competency hearing and . . . he had incorporated his new counsel into his conspiracy delusions,” neither fact was “inconsistent with the trial court’s original conclusion that [the defendant], although mentally ill, was nonetheless competent to stand trial.” Id. at 44 ¶ 30; see also Evans, 125 Ariz. at 403–04 (concluding there was a competent waiver of counsel despite defendant having been “diagnosed as a paranoid schizophrenic”). ¶47 A trial court “may order the defendant to undergo a preliminary examination” to assis

22
State v. Howlandgreen
arizctapp · 1982 · cited in 1 Arizona opinions naming this issue, 2022–2022
1 sentence

2022See State v. Howland, 134 Ariz. 541, 549 (App. 1982); see also LaCount v. Mroz, 253 Ariz. 49 , 52-54, ¶¶ 8-11 (App. 2022) (although it may have been prudent for the superior court to take the “limited step” of ordering a preliminary examination under Rule 11.2(c) “to assist the court in determining if reasonable grounds exist[ed] to order the defendant’s further examination,” such an order was discretionary). ¶28 In short, aside from defense counsel stating she was “not sure where [Rowan was] at mentally right now,” Rowan’s suicide attempt and treatment was the only information in the record c

11
United States v. Jack Apontegreen
ca9 · 1978 · cited in 1 Arizona opinions naming this issue, 1980–1980
1 sentence

1980See U. S. v. Aponte, supra. At the hearing in which appellant was found competent to stand trial, he was diagnosed as a paranoid schizophrenic.

11
State v. Martingreen
ariz · 1967 · cited in 1 Arizona opinions naming this issue, 1974–1974
2 sentences

1974Otherwise the constitutional right to defend oneself if he intelligently and competently chooses would be illusory.” State v. Martin, 102 Ariz. 142, 145 , 426 P.2d 639, 642 (1967).

1974Otherwise the constitutional right to defend oneself if he intelligently and competently chooses would be illusory.” State v. Martin, 102 Ariz. 142, 145 , 426 P.2d 639, 642 (1967).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (4)

CaseCitedYears
State v. Anderson green
ariz · 1964
2 sentences

1974In the same breath, however, once it is determined that a competent waiver has been made it is not within the province of the trial judge to thrust counsel upon the defendant. * * * “* * * While it is right that the court should indulge in every reasonable presumption against a waiver, see State v. Anderson, 96 Ariz. 123 , 392 P.2d 784 , this in no way implies that it should refuse to consider the defendant’s request altogether.

1974In the same breath, however, once it is determined that a competent waiver has been made it is not within the province of the trial judge to thrust counsel upon the defendant. * * * “* * * While it is right that the court should indulge in every reasonable presumption against a waiver, see State v. Anderson, 96 Ariz. 123 , 392 P.2d 784 , this in no way implies that it should refuse to consider the defendant’s request altogether.

21966–1974
State v. Glassel green
ariz · 2005
1 sentence

2022In Glassel, although the defendant’s “condition worsened after the original competency hearing and . . . he had incorporated his new counsel into his conspiracy delusions,” neither fact was “inconsistent with the trial court’s original conclusion that [the defendant], although mentally ill, was nonetheless competent to stand trial.” Id. at 44 ¶ 30; see also Evans, 125 Ariz. at 403–04 (concluding there was a competent waiver of counsel despite defendant having been “diagnosed as a paranoid schizophrenic”). ¶47 A trial court “may order the defendant to undergo a preliminary examination” to assis

12022–2022
John Thomas Benton v. United States neutral
ca9 · 1965
2 sentences

1967Benton v. United States, 352 F.2d 59 (9th Circuit).

1967Benton v. United States, 352 F.2d 59 (9th Circuit).

11967–1967
Gideon v. Wainwright green
scotus · 1963
2 sentences

1966Although the right to assistance of counsel in certain phases of a criminal prosecution is fundamental to due process of law, State v. Anderson, 96 Ariz. 123 , 392 P.2d 784 ; Gideon v. Wainwright, 372 U.S. 335 , 83 S.Ct. 792 , 9 L.Ed.2d 799 , the exercise of that right is subject to the requirements of sound judicial administration.

1966Although the right to assistance of counsel in certain phases of a criminal prosecution is fundamental to due process of law, State v. Anderson, 96 Ariz. 123 , 392 P.2d 784 ; Gideon v. Wainwright, 372 U.S. 335 , 83 S.Ct. 792 , 9 L.Ed.2d 799 , the exercise of that right is subject to the requirements of sound judicial administration.

11966–1966

Where else courts name it

OH 35 (1991–2026) CA 25 (1966–2025) TX 25 (1999–2026) IA 21 (2010–2026) IL 20 (1895–2022) PA 16 (1952–2025) NC 13 (1890–2026) FL 9 (1976–2013) AZ 7 (1966–2023) NY 6 (1997–2019) WA 5 (2006–2024) OR 4 (1993–2020) LA 3 (1978–2014) ID 3 (1981–2021) MA 3 (2000–2016) TN 3 (2001–2011) NJ 2 (2018–2018) GA 2 (2020–2020) DC 2 (1978–2023) UT 2 (2017–2026)

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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