State v. Joseph A.

Citations

• 336 Conn. 247

Syllabus

Convicted of the crimes of assault of a disabled person in the third degree and disorderly conduct, the defendant appealed to the Appellate Court, claiming, inter alia, that the trial court had violated his constitutional right to counsel when it permitted him to represent himself during the pretrial stage of the proceedings without obtaining a valid waiver of that right. The Appellate Court affirmed the defendant's conviction, and the defendant, on the granting of certification, appealed to this court. Held: 1. The Appellate Court correctly concluded that the trial court had not abused its discretion in determining that the defendant's waiver of his right to counsel during the pretrial stage of the proceedings was knowing, intelligent and voluntary: the trial court did not abuse its discretion in determining that the defendant understood the nature of the charges against him, as the court, during its canvass of the defendant, ascertained that he was literate and had graduated high school, recited each of the charged offenses and the minimum and maximum penalties associated with them, and asked the defendant whether he understood the charges and penalties, to which he replied in the affirmative; moreover, the defendant could not prevail on his claim that his waiver was constitution- ally inadequate because the trial court did not make him aware of the dangers and disadvantages of self-representation, as the court pointedly questioned the defendant regarding his familiarity with the laws and rules of procedure for criminal trials, and explained that it would not be able to advise him if he proceeded as a self-represented party and that he would be expected to follow all of the rules and procedures applicable to attorneys, and the defendant acknowledged that he had In accordance with federal law; see 18 U.S.C. § 2265 (d) (3) (2018); we decline to identify any party protected or sought to be protected under a protective order or a restraining order that was issued or a