State v. Petteway

Summary

The court held that the defendant forfeited his constitutional right to self-representation through a repeated pattern of refusing transportation, failing to appear, threatening to leave, and otherwise delaying or disrupting trial proceedings. The trial court acted within its discretion when it reappointed standby counsel after the defendant refused to return for voir dire, particularly because he had been warned that unjustified nonappearance could result in loss of self-representation. The court affirmed the convictions and concluded that the defendant’s conduct could forfeit both his right to be present and his right to represent himself for the remainder of trial.