State v. Montes

MORTENSEN, Judge:

¶1 Christopher Montes had already been held in contempt of court three times when he asked his appointed counsel, "[D]o I need to head-butt you so that the judge will give me a new lawyer?" Based on this statement and other actions of Montes, the trial court ruled that Montes had impliedly waived or forfeited his right to counsel and would be required to represent himself. Montes soon repented, and his lawyer represented him for the rest of the trial, but not before opening statements and two significant witnesses had testified. Now convicted, Montes appeals. Because we…