State v. Madsen

¶1 This case involves a criminal defendant’s “right to appear and defend in person, or by counsel,” which is expressly protected by Washington Constitution article I, section 22. Kurt Madsen was first represented in a criminal proceeding by counsel appointed for him. Unhappy with counsel, Madsen moved to proceed pro se on three occasions, citing and quoting the relevant Washington constitutional provision. The trial court deferred ruling on the first two motions and instead appointed new counsel. Madsen’s third motion was formally denied the day before scheduled jury selection. We reverse the…