State v. Kazee

The State of Wisconsin (State) seeks review, requesting that this court clarify trial court duties when faced with a last-minute request to discharge counsel. In addition, we are asked to determine the appropriate remedy when the trial court fails to inquire about such a request. We determine that Terry Craig Kazee’s (Kazee) words "I don’t want him,” made during his counsel’s opening statement, was tantamount to a request for new counsel. Because no inquiry was made into Kazee’s request for new counsel, and we cannot discern from the record whether Kazee’s request had a substantial factual…