State v. Jordan, 305 Conn. 1

Summary

The Supreme Court of Connecticut held that Victor L. Jordan clearly and unequivocally invoked his constitutional right to self-representation before trial. The trial court therefore was required to conduct the canvass mandated by Practice Book § 44-3, and Jordan was not required to renew his request after the court effectively denied it. The court reversed the Appellate Court’s judgment affirming his conviction for first-degree reckless endangerment.

Holdings

1. A defendant clearly and unequivocally invokes the right to self-representation when, viewed in context, he expressly requests self-representation in writing and orally, even if the request is presented as an alternative to substitute counsel or includes a request for standby counsel.
2. A defendant who has clearly and unequivocally requested self-representation is not required to renew the request after the trial court denies it; failure to do so does not establish equivocation or abandonment when further requests reasonably would appear futile.
3. The trial court violated Jordan's Sixth Amendment right to self-representation by denying his clear request without conducting the Practice Book § 44-3 canvass, and the violation was structural error requiring automatic reversal and a new trial.
4. The trial court did not violate Jordan's Sixth Amendment confrontation right by excluding proposed questioning concerning Ringor's prior speeding tickets, license suspension, immigration status, or a possible civil action because the proposed inquiries were minimally relevant, speculative, lacked an adequate factual foundation, or risked prejudice and confusion.

Questions Presented

1. Whether Jordan clearly and unequivocally invoked his Sixth Amendment right to self-representation, thereby requiring the trial court to conduct the canvass required by Practice Book § 44-3.
2. Whether the trial court improperly restricted Jordan's Sixth Amendment right to cross-examine witness Ricardo Ringor concerning Ringor's prior traffic offenses, license suspension, immigration status, and possible civil action.
3. Whether the proper remedy for denial of the right to self-representation was reversal and a new trial.

Disposition

reversed_and_remanded