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State v. Langley

Citations

  • 273 P.3d 901
  • 351 Or. 652
  • 2012 WL 1038674
  • 2012 Ore. LEXIS 204

How courts have described this case

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

  • holding that the trial court erred by forcing the defendant to choose between self-representation and representation by current counsel, where the court had failed to first determine whether the defendant’s complaints about counsel were valid
  • observing that a defense lawyer’s motion to withdraw cannot, standing alone, “be treated as an implied waiver of a defendant’s right to counsel”
  • determining that the defen- dant’s request for new counsel coupled with refusal to be represented by current counsel did not constitute a know- ing, intelligent, and voluntary waiver of right to counsel
  • “A defendant may also elect to waive his or her right to counsel and proceed pro se”
  • “[R]ecalcitrant behavior toward counsel can move beyond noncooperation and become mis- conduct that defeats the ability of counsel to carry out the representation function.”
  • “A defendant’s conduct may serve as a valid waiver so long as the conduct adequately conveys the defendant’s knowing and intentional choice to proceed in court without counsel.”

Source: CourtListener parenthetical corpus (CC0).

Judges: De Muniz, Durham, Walters, Haselton, Gillette

Read full opinion on CourtListener

Cited by

22 cases in this archive cite this case; the 20 most cited are listed.

Cites

14 cases in this archive are cited by this case.

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Sourced from CourtListener / Free Law Project (CC0).

This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.