New York Court of Appeals
The People of the State of New York v. Arnold Reason
July 10, 197537 N.Y.2d 351
Summary
The New York Court of Appeals affirmed the conviction, holding that a defendant who is competent to stand trial and who makes a knowing, intelligent, and voluntary waiver of counsel after a thorough inquiry satisfies the competency requirement to proceed pro se. The dissent argued that competence to stand trial is distinct from competence to waive counsel and that the trial court’s inquiry was insufficient.