State v. Hoff

How far may a trial court go in rescuing a defendant from an inept pro se defense? Not as far as the court went in this case. On the State's appeal, we reverse an order granting a new trial.

On July 26, 1979, defendant pushed a fully clothed Craig Phelps into the swimming pool at the Aquarian Apartments in Tumwater. The next evening, Phelps, accompanied by Willie Durden, returned to defendant's apartment to secure an apology. An altercation ensued; Phelps hit defendant on the head with a beer mug and Phelps and Durden fled in their car with defendant in hot pursuit. Defendant chased them…