Waiver of Appointed Counsel by Being Combative

A defendant "forfeited" his right to appointed counsel by causing his first three lawyers to withdraw and physically threatening the fourth.

 

State v. Nisbet, 2016 BL 60371, Me., Cum-14-224, 2/25/16

     The Maine Supreme Court ruled that a defendant who constantly caused issues with his appointed counsel "forfeited" his right to that counsel when he caused his first three lawyers to withdraw and physically threatening the fourth lawyer appointed.

     The court also said that, in the alternative, the defendant waived his right to counsel by implication. The trial court also told the defendant several times that he had driven away qualified attorneys, and warned him that if he continued to misbehave he would be forced to continue without representation.

http://www.bloomberglaw.com/public/desktop/document/STATE_OF_MAINE_v_JOSHUA_R_NISBET_No_CUM14224_2016_BL_60371_Me_Feb?1458315821