Douglas I, 151 P.3d at 495.Douglas v. State ( Douglas II), 166 P.3d 61, 65 (Alaska App. 2007).Id. at 65.
. Douglas v. State, 166 P.3d 61, 88-89 (Alaska App. 2007). Moore v. State, 123 P.3d 1081, 1087 (Alaska App. 2005).
Douglas v. State, 166 P.3d 61, 85 (Alaska App. 2007); see also Jones v. State, 215 P.3d 1091, 1099 (Alaska App. 2009). Douglas, 166 P.3d at 85.
See Moore v. State, 123 P.3d 1081, 1087 (Alaska App. 2005). Douglas v. State, 166 P.3d 61, 88-89 (Alaska App. 2007) (quoting LaBrake v. State, 152 P.3d 474, 482-83 (Alaska App. 2007)). Id. at 89.
That said, a defendant may not obtain a new lawyer at public expense by purposely frustrating appointed counsel's efforts and then asserting that the attorney-client relationship has broken down.Douglas v. State, 166 P.3d 61, 88-89 (Alaska App. 2007). Id. at 89 (citing Coleman v. State, 621 P.2d 869, 881 (Alaska 1980)).
Barron-Katairoak did not object to Elzey's testimony on hearsay grounds and it is well-settled that a court does not err by admitting hearsay in the absence of an objection.Christian v. State, 276 P.3d 479, 489 (Alaska App. 2012) (citing Rusenstrom v. Rusenstrom, 981 P.2d 558, 560-61 (Alaska 1999); Bird v. Starkey, 914 P.2d 1246, 1248 n.1 (Alaska 1996); Savely v. State, 180 P.3d 961, 962 (Alaska App. 2008); Douglas v. State, 166 P.3d 61, 85 (Alaska App. 2007); Cassell v. State, 645 P.2d 219, 220-21 (Alaska App. 1982)). Barron-Katairoak next argues that the court committed plain error by allowing Elzey to testify that, in his view, Gordon's injuries were not consistent with a single backhand strike.
” Citing and quoting Douglas v. State , 166 P.3d 61, 85 (Alaska App. 2007). But the State was authorized to introduce evidence that Moran pleaded guilty to the two prior assault charges.
The general rule is that "personal difficulties or animosity between a defense attorney and a defendant will constitute a reason for removing the defense attorney if the attorney-client relationship has deteriorated to the point where the attorney is incapable of effective communication with the defendant or the attorney is incapable of objective decision-making about the case." Douglas v. State, 166 P.3d 61, 88-89 (Alaska App. 2007). But indigent defendants who have received court-appointed counsel are not entitled to counsel of their choice, nor to a "meaningful relationship with their attorney."
See Pierce v. State, 261 P.3d 428, 432-33 (Alaska App. 2011), and the cases discussed therein. See Rusenstrom v. Rusenstrom, 981 P.2d 558, 560 (Alaska 1999); Bird v. Starkey, 914 P.2d 1246, 1248 n. 1 (Alaska 1996); Savely v. State, 180 P.3d 961, 962 (Alaska App. 2008); Douglas v. State, 166 P.3d 61, 85 (Alaska App. 2007). 2. The confrontation clause objection to Aitalla's statements during the 911 call: Johnson's right to confront Aitalla was satisfied because Aitalla testified at Johnson's trial.
Offered for this purpose, Reed's judgement of conviction was not admissible. See Jones v. State, 215 P.3d 1091, 1099 (Alaska App. 2009), where we explained that "evidence of a criminal conviction is inadmissible hearsay under Alaska law if it is offered to prove that the defendant actually engaged in the conduct that would justify that conviction". Quoting Douglas v. State, 166 P.3d 61, 85 (Alaska App. 2007). However, the prosecutor could properly introduce evidence of the 2005 assault through K.B.'s testimony — which, as we are about to explain, is ultimately what happened.