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Rivas v. State

District Court of Appeal of Florida, Fourth District
Sep 11, 1996
679 So. 2d 358 (Fla. Dist. Ct. App. 1996)

Opinion

No. 95-3620.

September 11, 1996.

Appeal from Fifteenth Judicial Circuit Court, Palm Beach County, Edward A. Garrison, J.

Robert Friedman, West Palm Beach, for appellant.

Robert A. Butterworth, Attorney General, Tallahassee; and Don M. Rogers, Assistant Attorney General, West Palm Beach, for appellee.


We reverse appellant's conviction and remand for a new trial because the trial court allowed defendant to represent himself at trial, but did not conduct either a Nelson hearing or a Faretta hearing prior to allowing the trial to proceed as it did. If defendant had been represented by his court-appointed counsel throughout the trial, we might well have been able to find that the defendant's ambiguous statements did not require a Faretta hearing; however, the court's permitting him to represent himself without a Faretta hearing leaves us no alternative but to reverse.

Nelson v. State, 274 So.2d 256 (Fla. 4th DCA 1973), in which this court established the procedure for determining if a defendant is entitled to discharge his court-appointed counsel for ineffective assistance, approved in Hardwick v. State, 521 So.2d 1071 (Fla. 1988).

Faretta v. California, 422 U.S. 806, 95 S.Ct. 2525, 45 L.Ed.2d 562 (1975), holding that a defendant has the constitutional right to represent himself after the court makes a sufficient inquiry and is satisfied with defendant's responses. See Fla. R.Crim. P. 3.111(d).

DELL, KLEIN and PARIENTE, JJ., concur.


Summaries of

Rivas v. State

District Court of Appeal of Florida, Fourth District
Sep 11, 1996
679 So. 2d 358 (Fla. Dist. Ct. App. 1996)
Case details for

Rivas v. State

Case Details

Full title:HECTOR RIVAS, APPELLANT, v. STATE OF FLORIDA, APPELLEE

Court:District Court of Appeal of Florida, Fourth District

Date published: Sep 11, 1996

Citations

679 So. 2d 358 (Fla. Dist. Ct. App. 1996)