Crimes of Moral Turpitude

(D)Denial of the right to counsel.[123]  A defendant who waived the right to counsel at sentencing was held to have been adequately informed of the dangers of self-representation, and the court therefore rejected his claim of violation of his right to cross-examine the doctor whose report formed the basis for a dangerous offender sentence.[124]

[123] Alabama v. Shelton, 535 U.S. 654, 122 S.Ct. 1764 (2002) (suspended sentence that may result in deprivation of liberty cannot be imposed unless the defendant is afforded the assistance of counsel); United States v. Tucker, 404 U.S. 443 (1972); Burgett v. Texas, 389 U.S. 109 (1967).

[124] Lopez v. Thompson, 202 F.3d 1110 (9th Cir. 1997). A valid waiver of the right to counsel requires the court to go beyond general references to the consequences of waiving the right, and describe the specific dangers of self-representation. United States v. Hayes, 231 F.3d 663 (9th Cir. 2000) (noting the court had reversed 16 published cases on this ground since 1978, and giving model admonishment for use by district courts); Baker v. City of Blaine, 205 F.3d 1138 (9th Cir. 2000).