Sims v. State

Summary

The court held that a defendant may abandon an unequivocal request for self-representation when the district court did not conclusively deny the request and the totality of the circumstances shows abandonment. Sims's request was not conclusively denied because the court's statement that self-representation was not available "right now" left open a future request, and his subsequent cooperation with counsel and failure to renew the request demonstrated abandonment. The court therefore affirmed the judgment of conviction.