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DECISIONS n CRIMINAL PRACTICE reversing a defendant’s conviction for first-degree murder, the California Supreme Court ruled on April 10 that a trial court erred when it refused to let the defendant represent himself. People v. Dent, No. S024645. When Omar Dent III’s lawyers in his murder trial were late for court, the trial court had them removed as counsel, and substituted new counsel. Dent said that if he could not proceed with his original lawyers, he wanted to represent himself. The trial court denied Dent’s request. After he was convicted and sentenced to death, Dent appealed, arguing that the trial court erroneously denied him his right to self-representation. On automatic appeal, the California Supreme Court agreed with Dent, reversing his conviction and death sentence. It held that the trial court wrongly denied Dent’s right to self-representation as set forth by the U.S. Supreme Court in its 1975 case, Faretta v. California. The California court conceded, “the evidence against defendant was overwhelming, and our review of the record indicates defendant was vigorously and adequately represented, and received a fair trial.” But, it added, that it was “compelled” to reverse by Faretta’s recognition of a right to self-representation.

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