State v. Francis

Summary

The court held that the defendant was effectively self-represented while testifying because trial counsel declined to represent him and the trial court appointed them only as standby counsel. The defendant did not clearly and unequivocally invoke self-representation, and the court improperly made him choose between testifying and retaining counsel, so his waiver of counsel was not voluntary. Because the deprivation of counsel was structural error, the court ordered a new trial without requiring proof of prejudice.