Williams v. State
1977 Tex. Crim. App. LEXIS 1075, 549 S.W.2d 183 (1977)
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Rule of Law:
A defendant who knowingly and intelligently elects to represent himself at trial cannot later claim on appeal that the quality of his own defense amounted to a denial of effective assistance of counsel. Such a pro se defendant is bound by the same rules of procedure and evidence as an attorney.
Facts:
- The complaining witness, a liquor store manager, recognized appellant Williams on the sidewalk as the same man who had robbed her approximately two months prior.
- On October 24, 1973, she attempted to close the store, but Williams entered armed with a pistol.
- Williams demanded all the money from the complainant.
- After taking the money, Williams forced the complainant into a storeroom, ordered her to remove her clothes, and then raped her.
- Before leaving, Williams threatened to kill the complainant and her baby if she reported the incident to the police.
- At trial, Williams testified that he had previously lived with the complainant, had a consensual relationship with her, and was in Louisiana on the day of the offense.
- In rebuttal, the complainant testified that six days after the robbery, on October 30, 1973, Williams entered her apartment bathroom with two butcher knives, threatened her for calling the police, and raped her again.
Procedural Posture:
- Williams was indicted for the offense of robbery by firearm.
- At the trial court level, Williams was appointed counsel but also filed numerous pro se motions.
- The trial court granted Williams's request to personally conduct voir dire, cross-examine certain witnesses, and make closing arguments.
- A jury found Williams guilty.
- The trial court sentenced Williams to 25 years of imprisonment.
- Williams appealed his conviction to the Texas Court of Criminal Appeals, which is the court of last resort for criminal cases in Texas.
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Issue:
Does a defendant who elects to represent himself waive the right to later complain that the quality of his own defense, or errors resulting from his own actions, amounted to a denial of effective assistance of counsel?
Opinions:
Majority - Dally, Commissioner
Yes, a defendant who elects to represent himself cannot thereafter complain that the quality of his own defense amounted to a denial of 'effective assistance of counsel.' Citing the Supreme Court's decision in Faretta v. California, the court reasoned that the right of self-representation is not a license to ignore relevant rules of procedural and substantive law. The court must apply the same rules to all parties, whether represented by counsel or acting pro se. In this case, much of the otherwise inadmissible evidence, such as testimony about prior extraneous offenses, became admissible or its inadmissibility was waived due to the appellant's own questioning and conduct during the trial. Therefore, he cannot use the consequences of his own folly as a basis for appeal.
Concurring - Roberts and Phillips, JJ.
Yes, but with disagreement on a specific evidentiary point. The concurring judges agreed with the final judgment to affirm the conviction. However, they dissented from the portion of the majority opinion which held that the appellant's objection to the admission of medical records was not properly preserved for appellate review, believing the objection was legally sufficient.
Analysis:
This decision reinforces the principle from Faretta v. California, clarifying that the right to self-representation carries with it the responsibility to adhere to established legal rules. It establishes that defendants who act pro se are held to the same procedural standards as attorneys and cannot use their own legal errors or strategic failures as grounds for an ineffective assistance of counsel claim. This precedent serves as a significant deterrent to defendants considering self-representation, highlighting the inherent risks and preventing them from using their own incompetence as a tool to obtain a new trial. The ruling protects the finality of judgments by closing a potential loophole for defendants to sabotage their own defense.
