State v. Hoff

Summary

The court held that Hoff’s conduct was functionally equivalent to a voluntary waiver of his right to counsel because of repeated attorney-client breakdowns and his request to pursue an unethical defense strategy. However, the waiver was not knowingly and intelligently made because the district court failed to advise him of the dangers and disadvantages of self-representation before requiring him to proceed pro se. The conviction was therefore reversed and the case remanded for a new trial.