The People of the State of Colorado, Petitioner v. Allen Charles Bergerud, Respondent

Summary

The court reversed the court of appeals and remanded for further factual development concerning whether Bergerud knowingly, intelligently, and voluntarily waived counsel after choosing to proceed pro se. It held that counsel's opening statements did not amount to a guilty plea or judicial admission, but the record was insufficient to determine whether counsel undermined Bergerud's personal right to testify or failed to investigate his proposed self-defense theory. Justice COATS, joined by Justices RICE and EID, dissented, arguing that counsel's tactics implicated ineffective assistance rather than deprivation of Bergerud's personal trial rights.