State v. Williams

Citations

• 206 Conn. App. 539

Syllabus

Convicted of the crime of sexual assault in the second degree after a trial to the court, the defendant appealed to this court, claiming that the trial court deprived him of his constitutional right to the assistance of counsel by allowing him to represent himself and thereafter abused its discretion by failing to order a competency hearing or to appoint counsel for him. The defendant had been represented by three public defenders during pretrial proceedings before two different trial judges in the several months prior to trial, when he sought to dismiss the public defenders and to represent himself. After the defendant rejected the state's offer of a plea agreement, the court canvassed him regarding his request to represent himself, and found that he knowingly, intelligently and voluntarily waived his right to counsel and was qualified to represent himself. None of the public defenders at any time during those proceed- ings expressed concerns to the court about the defendant's competence to stand trial or indicated that he suffered from a mental illness or incapacitation. Held: 1. The trial court did not abuse its discretion in determining that the defen- dant was competent to represent himself and that he made a knowing, voluntary and intelligent waiver of his right to counsel: a. The record supported the court's finding that the defendant was competent to waive his right to counsel and to represent himself, as he had expressed his desire to represent himself on two occasions before different judges prior to being allowed to represent himself, he was consistently able to articulate logical reasons for that desire, his responses to the court during its canvass of him showed that he compre- hended the disadvantages and dangers of representing himself, and he indicated that he understood the elements of the crime with which he was charged and the range of penalties associated with a conviction. b. Contrary to the defendant's contentions, the court's canvass of him pr