State v. Richards

YETKA, Justice

(dissenting).

I dissent because I think the record clearly shows that the defendant’s request to serve as his own counsel was equivocal. In Faretta v. California, the United States Supreme Court framed the constitutional question presented in these cases as “whether a State may constitutionally hale a person into its criminal courts and there force a lawyer upon him, even when he insists that he wants to conduct his own defense.” Faretta v. California, 422 U.S. 806, 807, 95 S.Ct. 2525, 2527, 45 L.Ed.2d 562 (1975) (emphasis added). Under Faret-ta, the request must be clear and unequivo*267cal. Faretta, 422 U.S. at 835, 95 S.Ct. at 2541.

The question for this court then becomes whether the facts of this case support a conclusion that the defendant’s assertion of his right to self-representation was “clear and unequivocal.” For purposes of this case, it is important to note that the Faret-ta Court distinguished between a request for self-representation and a request for co-counsel. See Faretta, 422 U.S. at 810 & n. 5, 95 S.Ct. at 2529 & n. 5. Although the defendant in the present case made several motions in connection with his right to self-representation, most of his requests were conditioned on a demand for a particular co-counsel or a similar arrangement whereby some sort of an assistant or “legal advisor” would be provided to him. Other requests were conditioned on being assured the same sort of access to documents, research facilities, and investigations that an ordinary attorney would have. Unlike Far-etta, Richards never unconditionally asserted the right to represent himself.

At the August 16, 1988 hearing on this matter, the trial court repeatedly attempted to elicit from the defendant a simple declarative statement as to whether he was asking to be allowed to represent himself or for some sort of co-counsel/legal advisor arrangement. The defendant repeatedly refused to clarify his request. Finally, the court asked the defendant: “[W]hat is it that you want me to do here?” and the defendant replied: “At this point I don’t know.” This response is hardly a “clear and unequivocal” assertion of the right to self-representation as required by Faretta. On the contrary, it amounts to a revocation of the earlier compound assertions.

The record is replete with evidence of a defendant who has absolutely manipulated the system for years. He has exhausted two judges and four attorneys. His final request to serve as his own counsel was equivocal in the additional sense that he still maintained that he preferred a private attorney, but only if the attorney were acceptable to him. The fact is, however, that none of the attorneys he had worked with up to that point had been acceptable to him.

What Richards really wanted was to orchestrate the trial process, have an attorney whom he could use as an errand boy or puppet, and force the trial court into a Hobson’s choice where either alternative would result in a claim of reversible error. It would not be difficult to imagine, had the trial judge permitted Richards to represent himself, his being here on appeal, claiming that he was denied effective assistance of counsel because he requested, but was not given co-counsel. Accordingly, I believe that the trial court properly rejected Richards’ ambiguous demands and correctly appointed excellent and experienced trial counsel on his behalf. See Tuitt v. Fair, 822 F.2d 166, 174-77 (1st Cir.1987) (affirming trial court’s denial of defendant’s equivocal request to proceed pro se and a subsequent denial of petition for habeus corpus), cert, denied, 484 U.S. 945, 108 S.Ct. 333, 98 L.Ed.2d 360 (1987). For all of the above reasons, I would conclude that the defendant’s right to self-representation was not properly asserted and, therefore, was not violated by the trial court’s ruling.

Upon reaching the above conclusion, I must address the only other real issue in this case, namely, the refusal of the trial court judge to recuse himself on request. I would affirm the trial court on this issue for two reasons: First, the request for recusal was untimely. The defendant did not make the request until after there had been numerous pretrial proceedings and Judge Porter had been sitting on the case for almost a year. In light of this procedural history, it is obvious that the defendant was exploiting the system by use of this delay tactic. Second, the defendant has not preserved this issue for appeal. Richards’ failure to seek a writ of prohibition justifies barring him from raising this issue on appeal. State v. Cermak, 350 N.W.2d 328, 331 (Minn.1984).

In summary, while granting a new trial makes some sense in cases where there is a need to correct procedural unfairness or deter future police or prosecutorial misconduct, such concerns are not present in this *268case. I cannot join an opinion that would, without any legitimate reason, send a case back for trial that would needlessly consume scarce judicial resources and incur additional public expenses when exactly the same result is anticipated. I believe that a new trial in this case would not serve any useful purpose, therefore, I would affirm the conviction.