State of Minnesota v. Christopher Lawrence Hunt

This opinion is nonprecedential except as provided by
Minn. R. Civ. App. P. 136.01, subd. 1(c).

STATE OF MINNESOTA
IN COURT OF APPEALS
A25-0133

State of Minnesota,
Respondent,

vs.

Christopher Lawrence Hunt,
Appellant.

Filed November 3, 2025
Affirmed
Larkin, Judge

Sherburne County District Court
File No. 71-CR-21-1588

Keith Ellison, Attorney General, St. Paul, Minnesota; and

Dawn R. Nyhus, Sherburne County Attorney, George R. Kennedy, Assistant County
Attorney, Elk River, Minnesota (for respondent)

Cathryn Middlebrook, Chief Appellate Public Defender, Joseph McInnis, Assistant Public
Defender, St. Paul, Minnesota (for appellant)

Considered and decided by Bond, Presiding Judge; Ross, Judge; and Larkin, Judge.

NONPRECEDENTIAL OPINION

LARKIN, Judge

Appellant challenges his convictions of two counts of second-degree criminal

sexual conduct, arguing that the district court violated his rights to self-representation and

counsel. Appellant raises additional issues in a supplemental pro se brief. We affirm.
 FACTS

In November 2021, respondent State of Minnesota charged appellant Christopher

Lawrence Hunt with four counts of second-degree criminal sexual conduct. The victims

were Hunt’s daughter and stepdaughter, who were 16 years old or younger at the time of

the offenses. Hunt requested appointment of a public defender, and the district court

granted his request. The initial public defender who was assigned to represent Hunt was

replaced after a staffing change at the public defender’s office. For reasons not clear from

the record, Hunt’s public-defender assignment changed a second time, and the third public

defender represented Hunt throughout the remaining proceedings in district court. All

subsequent references to Hunt’s public defender in this opinion refer to his third—and

final—public defender.

When Hunt first appeared with his public defender in December 2022, she informed

the district court, “At this point in time [Hunt] has advised me he’s going to seek outside

counsel so I would ask that the Public Defender’s Office be discharged.” The district court

asked Hunt if he had hired a new lawyer. Hunt responded that he had not and that his plan

was to find one that he could “speak with and consult equally and fairly.” The district court

granted Hunt a continuance to hire private counsel.

Hunt had not obtained private counsel by the time of a pretrial hearing in September

2023. At that hearing, Hunt’s public defender informed the district court that she had

received an e-mail from Hunt advising her that she was fired. She asked the court to inquire

of Hunt regarding his desired representation. The district court asked Hunt, “Going

forward here is it your request to continue with the Public Defender’s Office, . . . are you

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going to be hiring a private lawyer, or are you going to try to represent yourself on this

complicated case?” Hunt responded:

Umm, right now I’m kind of conflicted or confused
because from my understanding my Public Defender is
supposed to be in contact with me and help me as far as
defending myself in my side of the case. I’ve barely had any
correspondence with her the whole time that she’s been my
Public Defender, and when I had asked her for proof of
discovery she told me that’s not something she was willing to
be able to do.

The district court informed Hunt that his attorney was in trial the prior week which

“puts her behind with communication with her other [clients],” explained to Hunt that

“what normally happens is the closer you get to the trial date the more attentive, more

involved the Public Defender’s Office becomes regarding trial preparation,” and asked

again whether Hunt wanted the public defender to represent him. Hunt responded:

Okay because I have yet to -- I haven’t heard anything
about any kind of agreements or talks through the prosecutor
or any kind of time or anything of what you’re speaking of --

....

-- through my Public Defender so I’m not aware or sure
of anything. I have no information at all as far as that goes.

The district court did not discharge the public defender.

At a pretrial hearing on March 25, 2024, when the district court called the case, Hunt

stepped forward but did not sit by his counsel. The court asked, “are you Mr. Hunt?” Hunt

responded, “I am here on his behalf, yes,” and identified himself as “Christopher from the

Hunt family.” As stated in his brief to this court, “[a]fter twice being threatened with the

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issuance of a warrant if he did not sit by his attorney at counsel table,” he relented.1 Then,

Hunt’s public defender informed the court:

At this point in time I just would like to advise the Court that
Mr. Hunt has advised me that I am no longer working for him;
I got this information over e-mail. I did attempt to call him.
He is now here present today. He confirmed that he does not
want to work with the Public Defender’s Office any longer. I
had previously sent him a Petition to go Pro Se. My
understanding is he is uncomfortable signing that document.

The public defender again asked the court to inquire of Hunt regarding his desired

representation. The following exchange occurred:

THE DEFENDANT: Umm, I would like to rebut being a ward
of the state.

THE COURT: No one is saying you’re a ward of the state. I
want to know . . . whether or not you’re going to be
representing yourself moving forward or whether or not you’ll

1
During this exchange, the district court warned Hunt that “if Cristopher Hunt is not here
then I’ll issue a warrant for his arrest. So I’ll leave it up to [you] whether you want to have
a seat” next to the public defender “or not.” And after rejecting Hunt’s request to hand
something to the bailiff, the court warned Hunt that “[y]ou need to make a decision whether
you’re going to sit next to [the public defender] or whether I’m going to issue a warrant for
Christopher Hunt who’s not here.” Hunt argues that the district court’s statements
“communicated to [him] that his explicit efforts to represent himself would land him in
jail” and that if Hunt “did not sit by his [public defender’s] side and accept her
representation, he would be placed in jail.” We reject Hunt’s argument that the district
court was threatening to arrest him if he attempted to represent himself in this matter.
Instead, the district court was merely enforcing the General Rules of Practice for the
District Courts, which provide: “The lawyers should address the court from a position at
the counsel table. If a lawyer finds it necessary to discuss some question . . . at the bench,
the lawyer may so indicate to the court and, if invited, approach the bench for the purpose
indicated.” Minn. Gen. R. Prac. 2.03(c) (emphasis added). The rules further provide that
“[w]henever these rules require that an act be done by a lawyer, the same duty is required
of a self-represented litigant.” Minn. Gen. R. Prac. 1.04. In sum, although Hunt had a right
to represent himself, he did not have a right to exercise that right in disregard of the rules
that govern all proceedings in district court.

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 hire a private lawyer or whether or not you’re going to continue
with [the public defender].

THE DEFENDANT: I would like to speak with you in private
if I could.

THE COURT: That doesn’t happen in District Court, there are
no private conversations; whatever you have to say you can say
it now in open court.

THE DEFENDANT: Okay.

THE COURT: So what’s the deal? Do you want [the public
defender] to continue to represent you?

THE DEFENDANT: Well I was just under the impression that
according to the law that if you’re represented by a Public
Defender you have no rights, and you become a ward of the
state.

The court informed Hunt that it was not aware of any law that would support Hunt’s

claim. The district court also informed Hunt that a jury trial was scheduled and asked

again, “Do you want [the public defender] to continue to represent you or are you going to

be representing yourself or hiring a private lawyer; what do you want to do?” The

following exchange occurred:

THE DEFENDANT: And we’re on the record?

THE COURT: Yes we are, everything is on the record. My
Court Reporter is taking down everything.

THE DEFENDANT: I just wanted to make sure that they had
a recording of you saying that I wasn’t a ward of the state.

THE COURT: Okay. No you’re not a ward of the state unless
there’s some other proceedings civil that makes you a ward of
the state.

THE DEFENDANT: Okay nope.

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 THE COURT: Okay.

THE DEFENDANT: I would just -- I guess I haven’t got to
talk to [my public defender] barely at all. I mean, the most I’ve
talked to her has been at court. There is no contact or
communication.

THE COURT: And again why is that? Because the last time
we were here it was some time ago.

THE DEFENDANT: I know.

THE COURT: And I know that you’ve been trying to file
pleading after pleading without her knowledge, involvement,
permission. Why haven’t you communicated with her?

THE DEFENDANT: I have communicated my concerns, and
every time that I’ve brought my concerns up to her she said
that it doesn’t exist and that it’s not something that she will file.

The court explained to Hunt that his public defender was an officer of the court and required

to abide by the rules of evidence and professional responsibility and that “if you want her

to do something illegal or outrageous obviously she’s not going to be doing that.”

After that exchange, the district court recessed the hearing so Hunt could confer

with his public defender. After the recess, Hunt’s public defender informed the court, “I

have spoken with Mr. Hunt this morning. It is my belief at this point in time that he would

like to retain the services of the Public Defender’s Office.” Hunt did not say or do anything

to contradict that assertion.

In August 2024, jury selection began in Hunt’s case. On the second day of voir dire,

Hunt pleaded guilty with the assistance of his public defender. He proffered a petition to

plead guilty in which he affirmed, “I am satisfied that my attorney has represented my

6
interests and has fully advised me.” The district court sentenced Hunt to serve concurrent

sentences totaling 108 months in prison.

Hunt appeals.

DECISION

I.

Hunt contends that the district court violated his constitutional right to self-

representation.2 We review the denial of a defendant’s request to represent himself for

clear error. State v. Blom, 682 N.W.2d 578, 613 (Minn. 2004). “If the defendant’s right to

self-representation is violated, he is entitled to a reversal and new trial.” Id.

Under the Sixth and Fourteenth Amendments to the United States Constitution, a

criminal defendant has the right to defend himself in a state criminal proceeding. Faretta

v. California, 422 U.S. 806, 818-19 (1975); State v. Richards, 456 N.W.2d 260, 263 (Minn.

1990). “When a criminal defendant asks to represent himself, the court must determine (1)

whether the request is clear, unequivocal, and timely, and (2) whether the defendant

2
We note that, generally, a valid guilty plea waives any non-jurisdictional errors. Dikken
v. State, 896 N.W.2d 873, 878 (Minn. 2017); see Tollett v. Henderson, 411 U.S. 258, 267
(1973) (“[A] guilty plea represents a break in the chain of events which has preceded it in
the criminal process. When a criminal defendant [pleads guilty] . . . he may not thereafter
raise independent claims relating to the deprivation of constitutional rights that occurred
prior to the entry of the guilty plea.”); Korman v. State, 262 N.W.2d 161, 161 (Minn. 1977)
(holding that petitioner’s claims “relating to the deprivation of the right to counsel at the
initial appearance in municipal court and the admissibility of his confession, are both issues
waived by petitioner’s voluntarily, knowingly, and understandingly entered guilty plea.”).
The parties did not raise or address this issue in their briefing, and there was no request for
oral argument. We assume without deciding that Hunt’s constitutional claims are properly
before us even though he pleaded guilty.

7
knowingly and intelligently waives his right to counsel.” Blom, 682 N.W.2d at 613

(quotation omitted).

Hunt argues that the district court violated his right to self-representation because

he “made unequivocal, timely, and repeated efforts to act as his own counsel, but the

[district] court never permitted him to do so.” Specifically, Hunt asserts that his request

was unequivocal based on his “words and actions,” arguing that his actions at the March

25, 2024 hearing “reflect an unequivocal request to represent himself” for three reasons:

(1) when the hearing began, he “stood apart from his attorney in the courtroom,” (2) when

asked by the court if he was Hunt, he said he was “here on his behalf,” and (3) he “asked

if he could ‘hand something’ to the bailiff.”

At the March 2024 hearing, shortly after Hunt stated that he was present “on his

behalf,” the district court asked Hunt, “I want to know . . . whether or not you’re going to

be representing yourself moving forward or whether or not you’ll hire a private lawyer or

whether or not you’re going to continue with [the public defender].” Hunt did not answer

that question, much less say that he wanted to represent himself. Instead, Hunt asked to

speak to the judge in private and explained that he was “under the impression that according

to the law that if you’re represented by a Public Defender you have no rights, and you

become a ward of the state.” Hunt then raised concerns about his limited communication

with his public defender. However, after the district court recessed the hearing and allowed

Hunt an opportunity to confer with his public defender, Hunt’s public defender informed

the court, “I have spoken with Mr. Hunt this morning. It is my belief at this point in time

8
that he would like to retain the services of the Public Defender’s Office.” Hunt did not

refute his public defender’s statement.

The district court had twice previously addressed the issue of Hunt’s representation.

At a December 5, 2022 hearing, after learning that Hunt had told his public defender that

he wanted to seek outside counsel, the district court asked Hunt, “What is the plan in that

regard?” Hunt responded that he was going to find an attorney that he could “speak with

and consult equally and fairly,” and that he was “going to see what [he could] do” about

affording a private a lawyer. But Hunt did not say that he wanted to represent himself.

And at a September 18, 2023 hearing, after Hunt’s public defender advised the court that

Hunt sent her an email stating that she was fired, the district court specifically asked Hunt,

“Going forward here is it your request to continue with the Public Defender’s

Office, . . . are you going to be hiring a private lawyer, or are you going to try to represent

yourself on this complicated case?” Hunt responded that he was “conflicted or confused”

because he had concerns about the representation he was receiving from the public

defender. But again, Hunt did not say that he wanted to represent himself.

In sum, the district court specifically asked Hunt about his desired form of legal

representation at three different hearings. In response, Hunt provided equivocal answers

and expressed general dissatisfaction with his public defender’s representation. And when

the district court specifically asked Hunt if he wanted to be represented by his public

defender, hire a private attorney, or represent himself, Hunt never said that he wanted to

represent himself. In a case with similar facts, the supreme court determined that a

defendant’s request for self-representation was equivocal. See Blom, 682 N.W.2d at 613

9
(noting that defendant’s “request was equivocal as shown by his responses when the district

court asked him three times whether he was requesting to represent himself” and “[h]e did

not answer the questions clearly”). And, the facts here do not compare with caselaw

examples of unequivocal requests for self-representation. See Richards, 456 N.W.2d at

263-64 (concluding that defendant unequivocally asserted his right to self-representation

when he filed two written motions demanding his right to self-representation).3

Finally, Hunt argues that his repeated filings directly with the district court, attempts

to discharge his attorney, and “refusal to sign the Petition to Proceed as Pro Se Counsel

was behavior that showed Hunt wanted to represent himself.” Submission of an executed

petition to proceed as pro se counsel would have clearly communicated a desire for self-

representation, but the record shows that Hunt’s public defender provided him with such a

petition and Hunt would not sign it. Hunt’s principal appellate brief asserts that his failure

to sign the petition was “presumably due to his sovereign-citizen beliefs, but not because

he did not want to represent himself.” Although Hunt’s public defender informed the

district court that her “understanding” was that Hunt was “uncomfortable signing that

3
As support for his arguments on appeal, Hunt cites nonprecedential decisions of this court,
as well as a federal opinion, United States v. Oreye, 263 F.3d 669 (7th Cir. 2001), and state
court decisions from California. None of those decisions are binding on this court. And
because we do not find them persuasive, we do not discuss them. See Minn. R. Civ. App.
P. 136.01, subd. 1(c) (“Nonprecedential opinions and order opinions are not binding
authority . . . but . . . may be cited as persuasive authority.”); see also Citizens for a
Balanced City v. Plymouth Congregational Church, 672 N.W.2d 13, 20 (Minn. App. 2003)
(explaining that this court is bound by decisions of the United States Supreme Court but
not the decision of any other federal court); State v. McClenton, 781 N.W.2d 181, 191
(Minn. App. 2010) (observing that this court is not bound to follow precedent from other
state courts), rev. denied (Minn. June 29, 2010).

10
document,” Hunt never explained his refusal to sign the document. On this record, the

reason why Hunt refused to sign the petition is unknown, and we cannot make that factual

determination. See In re Welfare of M.D.O., 462 N.W.2d 370, 375 (Minn. 1990) (holding

that the role of the court of appeals is to correct errors, not to find facts).

In sum, the issue before us is whether Hunt made a clear, unequivocal request to

represent himself. See Richards, 456 N.W.2d at 263. An “unequivocal” request is one that

is “[u]nambiguous; clear; free from uncertainty.” Black’s Law Dictionary 1845 (12th ed.

2024) (defining unequivocal). Hunt never clearly and unambiguously communicated a

desire to represent himself. Although his words and conduct may have suggested some

interest in self-representation, when the district court repeatedly and specifically asked

Hunt if he wanted to represent himself, he never once said, “Yes.” And when his public

defender provided him with a petition to proceed pro se, he declined to sign it. Because

Hunt did not make an unequivocal request to represent himself, the district court did not

deny his right to self-representation.

II.

Hunt contends that the district court violated his Sixth Amendment right to counsel

by failing to conduct a searching inquiry after Hunt expressed concerns about the quality

of his public defender’s representation. The relevant law is set forth in State v. Munt:

The United States and Minnesota Constitutions
guarantee a criminal defendant the right to the assistance of
counsel for his defense. If the defendant cannot employ
counsel, the defendant is entitled to appointed counsel. But the
right of an indigent defendant to court-appointed defense
counsel is not an unbridled right to be represented by counsel
of the defendant’s choosing.

11
 When a defendant raises complaints about the
effectiveness of appointed counsel’s representation and
requests substitute counsel, the district court must grant such a
request only if exceptional circumstances exist and the demand
is timely and reasonably made. Exceptional circumstances are
those that affect appointed counsel’s ability or competence to
represent the client. But a defendant’s general dissatisfaction
with appointed counsel does not amount to an exceptional
circumstance. When the defendant voices serious allegations
of inadequate representation, the district court should conduct
a searching inquiry before determining whether the
defendant’s complaints warrant the appointment of substitute
counsel.

831 N.W.2d 569, 586 (Minn. 2013) (emphasis added) (quotations and citations omitted).

We review the district court’s decision whether to appoint substitute defense counsel

for an abuse of discretion. Id. “A district court abuses its discretion when its decision is

based on an erroneous view of the law or is against logic and the facts in the record.” State

v. Hallmark, 927 N.W.2d 281, 291 (Minn. 2019) (quotation omitted).

Hunt complains that, despite his expressed concerns regarding his public defender’s

representation, “the court never held any hearing and never inquired at all to determine if

there were exceptional circumstances that necessitated the removal of [his] appointed

counsel.”

Hunt argues that he notified the district court that: (1) his public defender did not

treat him “fairly and equally,” (2) his public defender did not adequately communicate with

him, and (3) his public defender failed to provide him with discovery. The record also

reveals that Hunt additionally complained to the district court that his public defender

refused to file certain motions on his behalf.

12
 In Munt, the defendant complained to the district court that his attorney did not

represent his interest, did not pursue his objectives, and was ineffective. 831 N.W.2d at

586-87. The supreme court determined that the district court did not err by failing to

investigate those allegations because, although the defendant “may have been dissatisfied

with his defense counsel,” none of “his statements constituted serious allegations of

inadequate representation that would have triggered the district court’s duty to further

inquire and determine whether it needed to appoint substitute counsel.” Id. at 587.

The supreme court explained that a searching inquiry should be conducted when a

defendant “voices serious allegations of inadequate representation” and that “a defendant’s

general dissatisfaction with appointed counsel does not amount to an exceptional

circumstance.” Id. at 586 (quotations omitted). Finally, the supreme court noted that “the

district court permitted [the defendant] to confer privately with counsel, and after the

recess, defense counsel represented to the court that he and [the defendant] were ‘on track’

and ‘everything is fine to go.’” Id. at 587. The supreme court thus concluded that the

defendant’s “acquiescence in defense counsel’s continued representation confirms that the

district court did not err by failing to make an additional inquiry into [the defendant’s]

complaints.” Id.

During these proceedings, Hunt implied that his public defender treated him

unfairly, and Hunt complained that his public defender failed to adequately communicate

with him, failed to provide him with discovery, and refused to file motions that he had

requested. These are similar to the Munt defendant’s complaints that his attorney did not

represent his interest, did not pursue his objectives, and was ineffective. Those types of

13
complaints reveal only a general dissatisfaction with counsel’s representation, which is

insufficient to trigger a searching inquiry. See Id. at 586.

Although the supreme court has stated that, in certain circumstances, disagreements

over trial strategy could affect an appointed attorney’s ability or competence to represent a

defendant, State v. Gillam, 629 N.W.2d 440, 449-50 (Minn. 2001), Hunt does not argue

that counsel’s refusal to file the motions that he requested suggested inability or

incompetence on the part of his public defender. And as to Hunt’s discovery complaint,

the record shows that, after Hunt alleged that his counsel “wasn’t able to send [discovery],”

Hunt’s counsel informed the court:

Your Honor, he has had and received several copies of
the discovery. The last time I advised him it would be at the
office for him to pick up. It involves children and confidential
information regarding those children; I did not feel
comfortable mailing it, and he has refused to pick up the
discovery. To the best of my knowledge, it is still sitting at the
front desk, and he is refusing to pick it up, and I just am very
uncomfortable just putting it in the U.S. Mail with the
confidentiality involving children.

In sum, because Hunt expressed only general dissatisfaction with his public

defender and did not make serious allegations of inadequate representation stemming from

his public defender’s ability or competence, the district court did not err by failing to

conduct a searching inquiry based on Hunt’s complaints. Like the supreme court in Munt,

we are influenced by the fact that the district court permitted a recess so Hunt could meet

privately with his public defender to discuss his concerns, and we conclude that Hunt’s

subsequent “acquiescence in defense counsel’s continued representation” confirms that the

14
district court did not err by failing to further inquire into Hunt’s complaints. Munt, 831

N.W.2d at 587.

Because the record does not reveal exceptional circumstances that affected the

public defender’s ability or competence, the district court did not violate Hunt’s right to

counsel by failing to perform a searching inquiry based on Hunt’s complaints.

III.

We now turn to the issues in Hunt’s pro se supplemental brief. When considering

pro se arguments, several principles govern our review. Courts have a duty to reasonably

accommodate pro se litigants, so long as there is no prejudice to the adverse party. Kasson

State Bank v. Haugen, 410 N.W.2d 392, 395 (Minn. App. 1987). “Although some

accommodations may be made for pro se litigants, this court has repeatedly emphasized

that pro se litigants are generally held to the same standards as attorneys and must comply

with court rules.” Fitzgerald v. Fitzgerald, 629 N.W.2d 115, 119 (Minn. App. 2001).

An appellate court “generally will not decide issues which were not raised before

the district court, including constitutional questions of criminal procedure.” Roby v. State,

547 N.W.2d 354, 357 (Minn. 1996). Failure to raise an issue “before the district court at

trial precludes its litigation on appeal.” Id. In addition, “[c]laims in a pro se supplemental

brief that are unsupported by either arguments or citation to legal authority are forfeited”

unless “prejudicial error is obvious on mere inspection.” State v. Montano, 956 N.W.2d

643, 650-51 (Minn. 2021) (quotations omitted).

Finally, a party must cite the record in support of factual assertions. See Minn. R.

Civ. App. P. 128.02, subd. 1(c) (stating that “[e]ach statement of a material fact shall be

15
accompanied by a reference to the record”). The record on appeal consists of “[t]he

documents filed in the [district] court, the exhibits, and the transcript of the proceedings, if

any.” Minn. R. Civ. App. P. 110.01. This court will not consider any factual assertions

that are beyond the record. See Plowman v. Copeland, Buhl & Co., 261 N.W.2d 581, 583

(Minn. 1977) (stating that “[i]t is well settled that an appellate court may not base its

decision on matters outside the record on appeal”).

Hunt appears to assert that his guilty plea was involuntary because his “signature

was affixed with ‘V.C.,’” which he claims is a “legal term [that] signifies that a contract or

agreement was made under duress, threat, or coercion, rendering it invalid.” Hunt also

asserts that the district court violated his “Sixth Amendment right to effective assistance of

counsel and the right to present a complete defense.” But Hunt’s assertions rely on extra

record documents that we cannot consider. Id. And, Hunt does not set forth the applicable

legal standards or provide any legal analysis to support his assertions. See Strickland v.

Washington, 466 U.S. 668, 687 (1984) (setting forth legal standard used to determine if a

defendant received ineffective assistance of counsel); Dikken, 896 N.W.2d at 876-77

(setting forth legal standard used to determine whether a guilty plea was involuntary).

Because prejudicial error is not obvious on mere inspection, these issues are forfeited. See

Montano, 956 N.W.2d at 650-51.

In sum, Hunt’s pro se supplemental brief does not provide a basis for relief.

Affirmed.

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