Ervin James Horton v. Richard L. Dugger, T.L. Barton

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• r equest untimely because meaningful trial proceedings had taken place since a jury had been selected
• “Appellate courts routinely uphold the discretion of trial courts to deny as untimely requests made after ‘meaningful trial proceedings’ have begun.” (quoting United States v. Smith, 780 F.2d 810, 811 (9th Cir. 1986))
• request untimely when made 15 minutes before trial was to begin
• “The functional right of a defendant to withdraw his request to represent himself and reassert the right to counsel at any time immediately before, or perhaps even during trial, is, absent deliberate manipulation, virtually assured.” (emphasis added)

Source: CourtListener parenthetical corpus (CC0).