State v. Spencer - 519 N.W.2d 357 (Iowa 1994)

Rule:

The Sixth Amendment provides that an accused shall enjoy the right to have the assistance of counsel for his defense. The Fourteenth Amendment of the federal constitution extends this right to state prosecutions. The right to self-representation to make one's own defense is necessarily implied by the structure of the Sixth Amendment. However, there is an important limitation on that right. Although the defendant may elect to represent himself, usually to his detriment, the trial court may--even over objection by the accused--appoint a "standby counsel" to aid the accused if and when the accused requests help, and to be available to represent the accused in the event that termination of the defendant's self-representation is necessary. Such an appointment serves to relieve the judge of the need to explain and enforce basic rules of courtroom protocol or to assist the defendant in overcoming routine obstacles that stand in the way of the defendant's achievement of his own clearly indicated goals. A case may be too complicated to allow self-representation. 

Facts:

Joseph Spencer told the trial court that he wished to represent himself, but admitted that he did not know legal procedures or how to object to improper evidence. The trial court appointed an attorney to represent Spencer. Spencer appealed after he was convicted contending that he was denied his right to self-representation. The court of appeals affirmed his conviction.

Issue:

Did Spencer suffer a violation of his sixth amendment right to self-representation when the district court appointed counsel for him over his objection?

Answer:

No.

Conclusion:

The court agreed with the court of appeals' conclusion that Spencer waived his U.S. Const. amend. VI right to self-representation because he made his request out of frustration and later abandoned any further assertions of that right. The court determined that the trial court did not err in appointing an attorney for Spencer to provide him with standby counsel. The court explained that the record evinced Spencer’s initial desire to be represented by counsel, so even if he wished to proceed pro se at the time of the withdrawal hearing, he waived and abandoned that right by acquiescing to the attorney's full representation of his case for the following year leading up to and during the jury trial. The court concluded that Spencer did not point to anything that he would have done differently had he represented himself at trial.