State v. L. Hogues

Summary

The court upheld the defendant’s waiver of counsel because the record showed that his decision to represent himself was voluntary, unequivocal, knowing, and intelligent. It nevertheless reversed his conviction because the State and District Court failed to make the case-specific showings and findings required to permit the alleged victim to testify remotely, and the defendant did not personally waive his face-to-face confrontation right. The conviction was remanded for a new trial.