People v. Waldon

Summary

The court held that the trial judge abused his discretion by granting Waldon's renewed request for self-representation without considering a prior judge's contrary ruling and the evidence supporting it. The renewed hearing also failed to establish that Waldon's waiver of counsel was knowing and voluntary or that he could competently present a defense. Because the error resulted in a total deprivation of counsel and was structural, the court reversed the judgment in its entirety and remanded for further proceedings.