People v. Crayton

Summary

The California Supreme Court held that a defendant who was fully advised of the right to counsel and knowingly waived that right in municipal court did not need to be readvised at superior court arraignment for purposes of the federal Constitution. Although the superior court violated California Penal Code section 987 by failing to readvise Timothy Crayton and obtain a new waiver, the error was subject to harmless-error review under People v. Watson and was nonprejudicial. The court affirmed the Court of Appeal’s judgment upholding the conviction.

Holdings

1. Yes. Penal Code section 987 required the superior court to inform an unrepresented defendant of the right to counsel and ask whether the defendant desired counsel at arraignment, even though Crayton had previously been advised and had waived counsel in municipal court.
2. No. The superior court's failure to readvise Crayton at arraignment was not an error of federal constitutional magnitude because he had previously received a full and adequate advisement and had knowingly and voluntarily elected self-representation throughout the proceedings.
3. No. The failure to readvise the defendant and obtain a renewed waiver at superior court arraignment is subject to harmless-error review under the Watson standard rather than automatic reversal.
4. No. There was no reasonable probability that Crayton was unaware of his right to appointed counsel or that he would have accepted counsel had the superior court repeated the advisement at arraignment.

Questions Presented

1. Whether the superior court violated the California statutory right to counsel by failing to readvise Crayton of his right to counsel and obtain a renewed waiver at arraignment on the felony information after he had knowingly waived counsel in municipal court.
2. Whether the failure to readvise Crayton and obtain a renewed waiver constituted federal constitutional error.
3. Whether the statutory error required automatic reversal or instead was subject to harmless-error review under People v. Watson.
4. Whether the error was prejudicial under the Watson standard on the record of this case.

Disposition

affirmed