The People of the State of Colorado v. Allen Charles Bergerud

Summary

The court reversed the court of appeals and remanded for further factual development concerning whether Bergerud's waiver of counsel was knowing, intelligent, and voluntary. It held that counsel's opening statements did not amount to a guilty plea or improperly appropriate Bergerud's right to enter a plea, but the record was insufficient to determine whether counsel undermined his right to testify or failed to reasonably investigate self-defense. Because proceeding pro se after an unconstitutional denial of substitute counsel would constitute a complete denial of counsel and structural error, the trial court was directed to conduct additional inquiries.