Supreme Court of Louisiana

State of Louisiana v. Reggie Patrick Thibodeaux

December 6, 2017236 So. 3d 1253

Summary

The court held that a trial court may not reflexively deny every pro se filing submitted by a defendant who is represented by counsel. Instead, the court must determine whether counsel will adopt the filing and, if not, assess its potential to cause confusion, disruption, or reversible error before deciding whether a hearing concerning self-representation is necessary. Justice Hughes concurred, emphasizing that an Alexander hearing is not required for every pro se filing and that counsel should first address legitimate motions with the client.