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7 Utah opinions name it 2 courts 1977–2021 1 in the last five years
The cases below were cited by Utah 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.
| Case | Followed | Cited |
|---|---|---|
Faretta v. Californiagreen2 sentences2018The “choice of self-representation often results in detrimental consequences to the defendant,” Bakalov, 1999 UT 45, ¶ 15 , but “a defendant who elects to represent himself cannot thereafter complain that the quality of his own defense amounted to a denial of ‘effective assistance of counsel,’” Frampton, 737 P.2d at 189 (quoting Faretta, 422 U.S. at 834‒35 n.46). 2018Cf. Faretta v. California , 422 U.S. 806 , 834 n.46, 95 S.Ct. 2525 , 45 L.Ed.2d 562 (1975) ( "[A] defendant who elects to represent himself cannot thereafter complain that the quality of his own defense amounted to a denial of 'effective assistance of counsel.' "). | 1 | 5 |
State v. Framptongreen2 sentences2018The “choice of self-representation often results in detrimental consequences to the defendant,” Bakalov, 1999 UT 45, ¶ 15 , but “a defendant who elects to represent himself cannot thereafter complain that the quality of his own defense amounted to a denial of ‘effective assistance of counsel,’” Frampton, 737 P.2d at 189 (quoting Faretta, 422 U.S. at 834‒35 n.46). 2018The "choice of self-representation often results in detrimental consequences to the defendant," Bakalov , 1999 UT 45 , ¶ 15, 979 P.2d 799 , but "a defendant who elects to represent himself cannot thereafter complain that the quality of his own defense amounted to a denial of 'effective assistance of counsel,' " Frampton , 737 P.2d at 189 (quoting Faretta , 422 U.S. at 834-35 n.46, 95 S.Ct. 2525 ). | 1 | 2 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Utah. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Rohwedder
green
1 sentence2021While “the choice of self-representation often results in detrimental consequences to the defendant,” the defendant “cannot thereafter complain that the quality of his own defense amounted to a denial of effective assistance of counsel.” Id. (cleaned up). ¶50 Bozarth has not pointed to any evidence indicating his waiver was invalid. | 1 | 2021–2021 |
State v. Bakalov
green
2 sentences2018The “choice of self-representation often results in detrimental consequences to the defendant,” Bakalov, 1999 UT 45, ¶ 15 , but “a defendant who elects to represent himself cannot thereafter complain that the quality of his own defense amounted to a denial of ‘effective assistance of counsel,’” Frampton, 737 P.2d at 189 (quoting Faretta, 422 U.S. at 834‒35 n.46). 2018The "choice of self-representation often results in detrimental consequences to the defendant," Bakalov , 1999 UT 45 , ¶ 15, 979 P.2d 799 , but "a defendant who elects to represent himself cannot thereafter complain that the quality of his own defense amounted to a denial of 'effective assistance of counsel,' " Frampton , 737 P.2d at 189 (quoting Faretta , 422 U.S. at 834-35 n.46, 95 S.Ct. 2525 ). | 1 | 2018–2018 |
State v. Penderville
green
2 sentences1977Faretta v. California, 422 U.S. 806 , 95 S.Ct. 2525 , 45 L.Ed.2d 562 (1975); State v. Penderville, 2 Utah 2d 281 , 272 P.2d 195 ; Utah Constitution, Art. 1, Sec. 12; Utah Code Annotated, Sec. 77-1-8(1) (1953). 3 . “. . whatever else may or may not be open to him on appeal, a defendant who elects to represent himself cannot thereafter complain that the quality of his own defense amounted to a denial of effective assistance of counsel.” Faretta, supra. 4 . 1977Faretta v. California, 422 U.S. 806 , 95 S.Ct. 2525 , 45 L.Ed.2d 562 (1975); State v. Penderville, 2 Utah 2d 281 , 272 P.2d 195 ; Utah Constitution, Art. 1, Sec. 12; Utah Code Annotated, Sec. 77-1-8(1) (1953). 3 . “. . whatever else may or may not be open to him on appeal, a defendant who elects to represent himself cannot thereafter complain that the quality of his own defense amounted to a denial of effective assistance of counsel.” Faretta, supra. 4 . | 1 | 1977–1977 |
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.