Cited by

See Maddox, d at 147; (inferring waiver after defendants fired their court-appointed attorneys); -13 (Minn. 1990) (inferring waiver from the “[d]efendant’s interaction with 12 different judges, his letters to those judges, his various conversations with two different public defenders, and his refusal to accept representation from the public defender’s office” and concluding that “the defendant was fully aw

Faretta, 422 U.S. at 807, 835 (stating that a defendant’s waiver of counsel must be knowing and intelligent, and observing that the record showed that the defendant was “voluntarily exercising his informed free will”); d 407, 412 (Minn. 1990) (stating that a defendant’s waiver of counsel must be knowing and intelligent); see also Minn. R. Crim.

ssatisfaction with his court-appointed attorney” did not constitute good cause to substitute appointed counsel and that his decision to discharge the public defender’s office “weighs in favor of a valid waiver of counsel.” Caselaw establishes that a “defendant’s refusal without good cause to proceed with able appointed counsel constitutes a voluntary waiver of that right.” (quotation omitted).

In State v. Krejci, the defendant appealed from his conviction and challenged the validity of his waiver of his right to counsel because the district court did not “advise him of the perils of proceeding pro se and failed to inquire into his reasons for rejecting the public defender.” .

1 (2016); (“The legislature has the authority, within the confines of the constitution, to enact special venue statutes and has done so when special needs relating to venue have arisen.”) .

at 8-9 (considering whether defendant had the benefit of standby counsel when determining validity of waiver); -13 (Minn. 1990) (concluding that waiver of counsel was valid and noting that the district court appointed the defendant ’s second public defender as standby counsel); Haggins, d at 90-91 (concluding that waiver of counsel was valid even though the district court did not initially offer standby counse

Gant, d at 9; -13 (Minn. 1990) (concluding that district court’s numerous reminders about defendant’s right to counsel over 19 pretrial appearances combined with defendant’s delay tactics provided “ample evidence” of knowing and voluntary waiver).

See Garibaldi, d at 830 (noting that the defendant was not “offered the benefit” of standby counsel); -13 (Minn. 1990) (noting that the court appointed the defendant’s second public defender as standby counsel); Haggins, d at 91 (noting that the district court offered standby counsel).

See, e.g., Fitch, d at 373 (venue challenge in jury-trial context); (venue challenge in court-trial context); (venue challenge in court-trial context); (venue challenge in jury-trial context), rev. granted (Minn. Nov.

“A defendant’s refusal without good cause to proceed with able appointed counsel constitutes a voluntary waiver of that right.” (citation omitted) (internal quotation marks omitted).

In State v. Krejci, the supreme court concluded that, although the district court “did not make the full, on-the-record inquiry wh ich is normally required to ensure a valid waiver,” the surrounding circumstances made clear that defendant “was fully aware of the consequences of proceeding pro se.” -13 (Minn. 1990).

d 270, 276 (Minn. 1998) (stating that an on-the-record inquiry concerning waiver of counsel was unnecessary where a defendant fired his attorney and had experience with the criminal justice system); see also State v. Krejci , -13 (Minn. 1990) (holding that an on-the-record inquiry concerning waiver of counsel was unnecessary where a defendant was unwilling to accept representation from public defenders and had extensive conversations on the matter with multiple judges).

1(3); see also State v. Krejci , (providing that the district court’s duty is “to ensure a knowing and intelligent waiver of the right to counsel”).

“A defendant’s refusal without good cause to proceed w ith able appointed counsel constitutes a voluntary waiver of that right.” (quotation omitted); see also Worthy, d at 277 (“A defendant’s refusal, without good cause, to allow appointed counsel to continue representation may by itself be sufficient to find a valid waiver.

ubargu ment of his jurisdictional argument, Janish also contended that he was entitled to a new t rial because the state, by introducing evidence on the counts over which the district cour t lacked jurisdiction, had introduced prior-bad-acts evidence without providing Spreigl notice.2 The district court 1 (concluding that venue was appropriate in the county where a child-abuse victim was hospitalized and the abuse was investigated).

The district court’s duty is “to ensure a knowing and intelligent waiver of the right to counsel.”

Appellant argues that her waiver was not knowing and intelligent because the district court “never meaningfully questioned her about whether she truly grasped th e ramifications of her decision ” as is required by State v. Krejci

But “[a]n indigent defendant does not have an absolute constitutional right to the counsel of his choice.”

Although some of our cases have generally discussed this right in terms of venue or the location of trial, see, (referring to Article I, Section 6, as a “constitutional provision[] relating to venue”), we recognized early on that Article I, Section 6, does not “expressly, or in effect, guaranty to the accused in all cases a trial in the county in which the offense was committed.” Robinson, 14 Minn. at 453

(stating that where a defendant fired his attorney and had familiarity with the criminal justice system, an on-the-record inquiry regarding waiver was unnecessary); -13 (Minn. 1990) (holding 2 We encourage district courts to use Form 11, Petition to Proceed As Pro Se Counsel, when establishing a waiver of the right to counsel.

When a crime implicates more than one county, the constitution does not require prosecution in “a single exclusive venue.” (quotation omitted).

-76 (Minn.1998); (stating that waiver was valid where defendant’s decision was “unequivocal” and “he was cognizant of the consequences of the decision”); -13 (Minn.1990) (stating that waiver may be valid if the record shows “that [a] defendant was fully aware of the consequences of proceeding pro se”).

But as this court noted in Larson, id., the supreme court’s implies that the venue statute is to be interpreted liberally.

2680, 2687 , 125 L.Ed.2d 321 (1993)); (stating that the district court has the duty to ensure that a defendant’s waiver of the right to counsel is knowing and intelligent).

“It is the duty of the trial court to ensure a knowing and intelligent waiver of the right to counsel.”

“It is the duty of the trial court to ensure a knowing and intelligent waiver of the right to counsel.”

(defendant who rejected public defender and was unable to obtain private counsel ordered to proceed pro se, but with standby counsel).

-11 (Minn.1990) (citing Minn.Stat.