Stanley Carl Rhinehart v. J. B. Gunn

Stanley Carl Rhinehart appeals a judgment dismissing his petition for a writ of habeas corpus under 28 U.S.C. § 2254. We vacate the judgment and remand the cause to the district court.

Under Meeks v. Craven, 482 F.2d 465, 466-68 (9th Cir. 1973), a state prisoner can successfully attack a state conviction in a federal habeas corpus challenge on self-representation grounds only if the prisoner made an unequivocal demand in the state court to be allowed to represent himself. In the § 2254 proceeding, the district court may rely on the opinion of the state courts on the factual underpinning of…