Wilson v. State

Steven Wilson was charged with the felony of resisting a lawful traffic stop. A week before trial, Wilson insisted upon waiving counsel and representing himself. The court initially resisted, then relented after a Faretta hearing1 on the record. The jury found Wilson guilty; he received a prison sentence; and no appeal was taken.

In his timely post-conviction motion,2 Wilson complained that “I was forced to be pro-se at my own Jury Trial.” The motion judge (previously the trial judge) denied relief without a hearing, finding in pertinent part that Wilson elected to represent himself and waived…