Cited by
Opinions in Minnesota that cite State v. Clark, 722 N.W.2d 460.
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State of Minnesota, Respondent,
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
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State of Minnesota, Respondent,
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, Respondent, 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, Respondent, Minn. Ct. App. 2023
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
d 460, 464 (Minn. 2006).
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State of Minnesota, Respondent,
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, Respondent, Minn. Ct. App. 2022
- State of Minnesota, Respondent, Minn. Ct. App. 2022
- State of Minnesota, Minn. 2021
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State of Minnesota, Respondent,
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).
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
See State v. Clark , -68 (Minn. 2006) (recognizing discretion is afforded to the district court).
- State of Minnesota, Respondent, Minn. Ct. App. 2021
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
State v. Clark , see also State v. Jones , (explainin g the role of advisory counsel).
- State of Minnesota, Respondent, Minn. Ct. App. 2020
- State of Minnesota, Respondent, Minn. Ct. App. 2020
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State of Minnesota, Respondent,
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, Respondent, Minn. Ct. App. 2020
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State of Minnesota, Respondent,
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, Respondent, Minn. Ct. App. 2020
- State of Minnesota, Respondent, Minn. Ct. App. 2019
- State of Minnesota, Respondent, Minn. Ct. App. 2019
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State of Minnesota, Respondent,
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
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
d 440, 449 (Minn. 2001) .
- State of Minnesota, Respondent, Minn. Ct. App. 2018
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State of Minnesota, Respondent,
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, Respondent, Minn. Ct. App. 2017
- State of Minnesota v. Taeng Yang Minn. Ct. App. 2017
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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
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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
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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
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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
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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).
- State v. Rhoads 813 N.W.2d 880 Minn. 2012