Butler v. State
The Second DCA affirmed a robbery conviction, holding that the trial court did not err in questioning defense counsel about his qualifications outside the defendant's presence because the defendant's mid-trial complaints about counsel were general dissatisfaction, not a clear and unequivocal request to discharge counsel sufficient to trigger a Nelson hearing, and any such request would have been untimely once trial began. The court also held the trial court's Faretta inquiry was adequate and did not need to be completed because the defendant abandoned his request for self-representation after being warned about the risks to future ineffective-assistance claims.
Key facts
- Defendant was convicted of robbery in trial court.
- During trial, defendant made general complaints about his appointed counsel's trial preparation, strategy, and witness development, and requested self-representation.
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Why it matters
This opinion is useful to practitioners handling Nelson/Faretta issues at trial because it reaffirms that mid-trial complaints about counsel's strategy and preparation, without an unequivocal request to discharge… — full analysis with a trial
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