Jan. 23, 2023 – People v. Waldon (Supreme Ct., S025520)

In an automatic appeal after a judgment of death, the Supreme Court reverses appellant’s conviction and sentence because of errors in granting his request to represent himself. The court finds the judge who granted appellant’s second Faretta motion abused his discretion by overturning the prior judge’s Faretta denial without considering her findings and the bases for her decision, and by ignoring relevant evidence, resulting in structural error for the “total deprivation of the right to counsel.”