South Carolina v. Samuel

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The South Carolina Supreme Court clarified the proper scope of a circuit judge's inquiry under Faretta v. California, 422 U.S. 806 (1975), when a criminal defendant knowingly, intelligently, and voluntarily waives his right to counsel and requests to proceed pro se. Lamont Samuel was indicted for the murder of his cousin, Taneris Hamilton. On the day his case was called to trial, Samuel indicated he was dissatisfied with defense counsel and made a Faretta motion to waive his right to counsel and proceed pro se. Rather than concluding the Faretta colloquy, the circuit judge continued to caution Samuel against representing himself, stating she did not believe he was sufficiently familiar with the law, procedure, or rules of evidence to adequately represent himself. Despite the judge's warnings and in light of the potential penalties he faced, Samuel voluntarily reaffirmed his desire to dispense with the assistance of counsel and proceed pro se. The circuit judge summoned the attorney Samuel alleged he had been coached by in order to proceed pro se, to question the attorney on his relationship with Samuel. The attorney's testimony conflicted with Samuel's asserted "coaching." The circuit judge interpreted Samuel's and the attorney's conflicting testimony to mean Samuel was lying to her and attempting to manipulate the proceedings. Samuel proceeded to trial with his counsel and was found guilty and sentenced to fifty years imprisonment. He appealed his conviction, asserting the circuit judge erred in denying his right to self-representation, and the court of appeals affirmed. The Supreme Court reversed, finding Samuel made a knowing, intelligent, and voluntary request to proceed pro se as required by Faretta, and he should have been given the opportunity to represent himself. View "South Carolina v. Samuel" on Justia Law