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Supreme Court Overturns Death Sentence

People v. Waldon Docket: S025520, Opinion Date: January 23, 2023. The Supreme Court reversed Defendant's conviction for three counts of first-degree murder and several other crimes, holding that the trial judge erred when he granted Defendant's request to represent himself after a different judge had previously denied the request. Before trial, Defendant filed a motion to exercise his right of self-representation under Faretta v. California, 422 U.S. 806 (1975). Judge Zumwalt denied the motion, concluding that Defendant had a mental disorder that prevented him from appreciating the ramifications of waiving counsel. More than one year later, Defendant filed a second Faretta motion before Judge Boyle. Without considering Judge Zumwalt's denial of the first Faretta motion or the evidence on which it was based, Judge Boyle granted the motion. The Supreme Court reversed, holding that Judge Boyle abused his discretion by overturning Judge Zumwalt's Faretta denial while intentionally ignoring the bases for the decision or relevant evidence and that the decision was not harmless.


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