Hirschfield v. Payne, 420 F.3d 922 (9th Cir. Aug. 22, 2005) (state court properly ruled that first Faretta motion was for purposes of delay, but second motion (made after case had to be delayed due to other reasons), which was denied by another judge on the basis that the defendant did not have sufficient legal knowledge to represent himself, was erroneous; because the appellate court did not address the second motion separately, the federal panel reviewed the trial court's oral decision, and found it contrary to clearly established federal law).

jurisdiction: 
Ninth Circuit

 

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