The People of the State of Colorado v. Paul Alex Lavadie

Summary

The court held that a defendant may represent himself only after validly waiving the right to counsel through a voluntary, knowing, and intelligent waiver assessed under the totality of the circumstances. A trial court need not specifically warn an uncooperative defendant that refusal to answer may result in appointed counsel, nor must it automatically revisit a prior finding that the waiver was deficient. Because Lavadie's repeated nonsensical and nonresponsive answers did not demonstrate an understanding of the right he was waiving, the trial court properly denied self-representation, and the court reversed the court of appeals.