Andrew L. Jackson v. Byran Bartow

Summary

Andrew Jackson v. Byran Bartow, 930 F.3d 930 (7th Cir. 2019): The Seventh Circuit held that a defendant's unconditional, knowing, and voluntary guilty plea waives any claim of pre-plea constitutional error, including the erroneous denial of the Sixth Amendment right to self-representation under Faretta v. California. The court found that the state trial court unreasonably applied Faretta by denying self-representation based on the defendant's lack of legal knowledge rather than mental incompetence, but the guilty plea nonetheless waived the claim. The structural nature of the self-representation error does not prevent waiver, and the defendant forfeited any argument that the plea itself was involuntary by failing to raise it in the district court.

Holdings

1. The Wisconsin Court of Appeals unreasonably applied Faretta when it relied on Jackson's lack of legal knowledge and skill to deny his request for self-representation, because Faretta focuses only on competence as it relates to mental functioning, not skill or knowledge.
2. A valid, unconditional guilty plea waives all pre-plea constitutional violations, including the denial of the right to self-representation at trial, even if that denial is a structural error.

Questions Presented

1. Whether the Wisconsin Court of Appeals unreasonably applied Faretta v. California in affirming the denial of Jackson's request for self-representation at trial.
2. Whether Jackson's unconditional guilty plea waived his claim of constitutional error regarding the denial of self-representation.
3. Whether the district court could raise the waiver defense sua sponte when the State did not plead it in its answer.
4. Whether the denial of self-representation is a structural error that overcomes the guilty plea waiver.

Disposition

affirmed