Petrie-Blanchard v. State
A pro se defendant convicted of first-degree murder was not offered renewed counsel before proceeding directly to sentencing following the jury's verdict. The Fifth DCA held that failure to renew the offer of counsel at sentencing is fundamental error requiring reversal, even where the sentence is mandatory life, and affirmed the conviction but reversed and remanded for resentencing with either appointed counsel or a valid waiver.
Key facts
- Petrie-Blanchard, a pro se defendant, was convicted of first-degree murder by jury verdict and proceeded directly to sentencing without being offered renewed counsel.
- The trial court did not renew the offer of counsel at sentencing despite the defendant's valid Faretta waiver having applied only to the trial phase.
- +2 more key facts with a free trial
Why it matters
This decision reinforces and extends the fundamental-error rule requiring renewal of the offer of counsel at sentencing even when a self-represented defendant faces a legally mandatory sentence like life imprisonment… — full analysis with a trial
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