State v. Paschal

Citations

• 207 Conn. App. 328

Syllabus

Convicted of attempt to commit assault of public safety personnel, the defendant appealed to this court. At a pretrial hearing, the defendant informed the trial court that he was dissatisfied with the representation provided by his public defender and requested that he be able to proceed as a self-represented party. The trial court determined that the defendant was mainly concerned with the speed at which the proceedings were progressing, denied the request without prejudice, asked the defendant to give defense counsel another chance to effectively represent him, and told the defendant that he could reassert his request at a later time. Approximately four months later, at another pretrial hearing, the defendant again indicated that he was frustrated with his defense counsel and the speed of the proceedings. He asked the trial court if he could have new counsel and then stated that he was reasserting his sixth amendment right to self-representation. The trial court told the defen- dant that he needed to file a motion if he wanted to represent himself. The defendant did not file such a motion and defense counsel continued to represent him without additional complaint until approximately nine months later, when the defendant personally filed several motions. Dur- ing a hearing on the defendant's motion for the removal of appointed counsel and appointment of new counsel, the defendant again asserted that his requests for self-representation and for new counsel were wrong- fully denied. He asked for the appointment of a special public defender to replace defense counsel, and he further indicated that he would not object to the appointment of new counsel. Thereafter, new counsel was appointed and the trial proceeded without the defendant making any additional requests for self-representation. Held: 1. The defendant could not prevail on his claim that the trial court deprived him of his right to self-representation because the defendant waived that right: the trial court d