Koehler v. State
Indiana Supreme Court
1Opinion of the Court
SHEPARD, Justice.
Today we deal with a "jailhouse lawyer" who realized his folly in electing self-representation but was prevented from correcting his mistake.
Appellant Kenneth "Robin" Koehler proceeded pro se before a jury against a charge of battery, a class C felony, Ind. Code § 85-42-2-1(8) (Burns 1985 Repl.). After the jury found him guilty of battery but before his habitual criminal hearing began, Koehler requested that his standby counsel take over the defense. The trial court refused his request, and Koehler continued to represent himself. He was found to be an habitual criminal,…
2Cases cited17 opinions
- Johnson v. ZerbstSupreme Court of the United States · 1938
- Faretta v. CaliforniaSupreme Court of the United States · 1975
- United States v. WadeSupreme Court of the United States · 1967
- Illinois v. AllenSupreme Court of the United States · 1970
- People v. WindhamCalifornia Supreme Court · 1977
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3Cited by35 opinions
- Henley v. StateIndiana Supreme Court · 2008
- Dowell v. StateIndiana Court of Appeals · 1990
- Hughes v. StateIndiana Supreme Court · 1989
- Williams v. StateIndiana Court of Appeals · 1994
- Sweeney v. StateIndiana Court of Appeals · 2008
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