City of Tacoma v. Bishop

Joseph R. Bishop appeals his conviction for two counts of indecent liberties on grounds that the trial court violated his constitutional right to counsel by requiring him to proceed to trial without counsel and without a valid waiver of that right. Finding that Bishop neither waived nor forfeited his right to counsel by his dil atory conduct, and that the municipal court erred in requiring him to represent himself at trial without a waiver or proper warnings, we reverse and remand.

FACTS

Bishop was charged with two counts of indecent liberties against C.P., the 10-year-old daughter of his…