Madison v. State

We are constrained to reverse Appellant’s conviction and remand this case for a new trial because the trial court designated Appellant as co-counsel without conducting an inquiry under Faretta v. California, 422 U.S. 806, 95 S.Ct. 2525, 45 L.Ed.2d 562 (1975), and without advising Appellant of the dangers of self-representation. See Brooks v. State, 703 So.2d 504 (Fla. 1st DCA 1997).

After designating Appellant co-counsel, the trial court allowed him to argue a pretrial motion and present lengthy arguments at his sentencing that essentially constituted requests for post-trial relief. While we…