State v. Janachovsky

Citations

• 2025 ND 30

Syllabus

A criminal defendant who advises the district court that he intends to represent himself, and does so at each hearing after acknowledging an understanding of the rights afforded to him, constitutes the functional equivalent of a voluntary waiver of counsel. A defendant knowingly and intelligently waives his right to counsel when he decides to represent himself after being advised the dangers and disadvantages of self-representation.