Cited by

Opinions in Minnesota that cite State v. Clark, 722 N.W.2d 460.

63 citing documents.

David Chukuma Jirinzu v. State of Minnesota Minn. Ct. App. 2026
State of Minnesota v. Angelette Marie Crumble Minn. Ct. App. 2026
We agree that it would be “an incorrect statement of the law to say that a criminal defendant may not have a different public defender under any circumstances.” (emphasis added), aff’ d
State of Minnesota v. Shawn Michael Tillman Minn. 2026
State of Minnesota v. Quenton Tyrone Williams Minn. Ct. App. 2026
Reappointment of Counsel A defendant who waives counsel “does not have an absolute right to relinquish the right of self-representation.” .
State of Minnesota v. Adrian Dominique Bell Minn. Ct. App. 2025
State of Minnesota v. Devon Griffin Seivers Minn. Ct. App. 2024
State of Minnesota v. Devon Griffin Seivers Minn. Ct. App. 2024
State of Minnesota v. Bryant Jerome Stephenson Minn. Ct. App. 2023
State of Minnesota v. Chad Lawrance Bachmeier Minn. Ct. App. 2022
d 460, 464 (Minn. 2006).
State of Minnesota v. Mark Franklin, Jr. Minn. Ct. App. 2022
d 270, 278-79 (Minn. 1998) ; see also State v. Clark , (holding that the defendant ’s request for substitute counsel was untimely when the request was made the morning that trial was to begin, after jury selection had begun, and when the defendant had made a speedy -trial demand) .
State of Minnesota v. Anthony Michael Bishop Minn. Ct. App. 2022
State of Minnesota v. Travis O’Neal Dillard Minn. Ct. App. 2022
State of Minnesota, Minn. 2021
State of Minnesota v. Dorale Dominique Brooks Minn. Ct. App. 2021
A defendant’s reque st for substitute counsel must be granted only if “exceptional circum stances exist and the demand is timely and reasonably made.” (quotations omitted).
State of Minnesota v. Edward Earl Williams Minn. Ct. App. 2021
See State v. Clark , -68 (Minn. 2006) (recognizing discretion is afforded to the district court).
State of Minnesota v. Marcus Angelo Caples-Guerra Minn. Ct. App. 2021
State of Minnesota v. Michael Ryan Tverberg Minn. Ct. App. 2020
State v. Clark , see also State v. Jones , (explainin g the role of advisory counsel).
State of Minnesota v. Brandon Michael James Opatz Minn. Ct. App. 2020
State of Minnesota v. Bruce Renault Fry Minn. Ct. App. 2020
State of Minnesota v. Shawn William Lampi Minn. Ct. App. 2020
While the Minnesota Constitution provides that defendants have a right to the assistance of defense counsel, see Minn. Const. art. I, § 6, the Minnesota Supreme Court has “decline[d] to read the Minnesota Constitution as 4 guaranteeing advisory counsel for pro se defendants[,]”
State of Minnesota v. Dominique Demetris Wright Minn. Ct. App. 2020
State of Minnesota v. Jimmy Lee Robinson Minn. Ct. App. 2020
If a defendant expresses “serious allegations” about an appointed attorney’s ability or competence, “the district court s hould conduct a 5 ‘searching inquiry ’ before determining whether the defendant ’s complaints warra nt the appointment of substitute counsel.” Munt, d at 586 (quoting State v. Clark , ).
State of Minnesota v. Derrick Lee Riddle Minn. Ct. App. 2020
State of Minnesota v. Omar Kwabena Walford Minn. Ct. App. 2019
State of Minnesota v. Micheal Anthony Sparks Minn. Ct. App. 2019
State of Minnesota v. Aaron Lavell Ross Minn. Ct. App. 2019
(concluding the defendant’s request for substitute counsel was untimel y when the defendant made the request after jury selection and a speedy trial demand); State v. Reed , (concluding that the defe ndant’s request for substitute c ounsel a week before trial
State of Minnesota v. Jeremy Shane Zimmermann Minn. Ct. App. 2019
d 440, 449 (Minn. 2001) .
State of Minnesota v. Johnny Frank Logan, III Minn. Ct. App. 2018
State of Minnesota v. Bradley Justin Miles Minn. Ct. App. 2018
“The decision to grant or deny a request for substitute counsel lies within the [district] court’s discretion.” State v. Clark
State of Minnesota v. Timothy Neal Grengs Minn. Ct. App. 2017
State of Minnesota v. Taeng Yang Minn. Ct. App. 2017
State of Minnesota v. Taeng Yang Minn. Ct. App. 2017
If a defendant voices “serious allegations” regarding counsel’s ability or competence, “the district court should conduct a ‘searching inquiry’ before determining whether the defendant’s complaints warrant the appointment of substitute counsel.” Munt, d 4 at 586 ().
State of Minnesota v. Melissa Rae Guillette Minn. Ct. App. 2016
State of Minnesota v. Melissa Rae Guillette Minn. Ct. App. 2016
“The decision to grant or deny a request for substitute counsel lies within the [district] court’s discretion.” ().
State of Minnesota v. Abel Gonyamonquah Miamen Minn. Ct. App. 2016
State of Minnesota v. Abel Gonyamonquah Miamen Minn. Ct. App. 2016
State of Minnesota v. Douglas John Olson 884 N.W.2d 395 Minn. 2016
State of Minnesota v. Douglas John Olson 884 N.W.2d 395 Minn. 2016
(subjecting a district court’s decision regarding whether it may appoint advisory counsel to an abuse-of-discretion standard of review).
State of Minnesota v. Shavelle Oscar Chavez-Nelson 882 N.W.2d 579 Minn. 2016
State of Minnesota v. Shavelle Oscar Chavez-Nelson 882 N.W.2d 579 Minn. 2016
State of Minnesota v. Rico Patrick Howard Minn. Ct. App. 2016
State of Minnesota v. Rico Patrick Howard Minn. Ct. App. 2016
State of Minnesota v. George Jerry Matlock, Jr. Minn. Ct. App. 2014
State of Minnesota v. George Jerry Matlock, Jr. Minn. Ct. App. 2014
Dobbins v. State 845 N.W.2d 148 Minn. 2013
Dobbins v. State 845 N.W.2d 148 Minn. 2013
See Ferguson, d at 816 ; (holding that the Minnesota Constitution does not guarantee advisory counsel for pro se defendants).
State v. Munt 831 N.W.2d 569 Minn. 2013
State v. Munt 831 N.W.2d 569 Minn. 2013
State v. Maddox 825 N.W.2d 140 Minn. Ct. App. 2013
State v. Maddox 825 N.W.2d 140 Minn. Ct. App. 2013
l not lightly reject a Supreme Court interpretation of identical or substantially similar language” and “will not cavalierly construe our constitution more expansively than the United States Supreme Court has construed the federal constitution” and has declined to extend the right to counsel under the Minnesota Constitution to “guaranteeing advisory counsel for pro se defendants.” (quotations omitted).