State v. Patten

Summary

The Supreme Court of South Dakota reversed Leigh Patten’s misdemeanor conviction for obstructing a law enforcement officer. The court held that Patten was denied her right to counsel because she requested appointed counsel, was required to proceed pro se after the request was denied, and was not advised of the dangers of self-representation or shown to have knowingly and intelligently waived counsel.

Holdings

1. Patten did not validly waive her constitutional right to counsel because the trial court did not warn her of the dangers and disadvantages of self-representation, and the record did not otherwise establish that she understood those dangers.
2. Indigence must be determined on a case-by-case basis and may not be resolved by resort to artificially predetermined financial standards or guidelines; the record indicated that the trial court denied counsel solely because Patten owned an interest in real estate.

Questions Presented

1. Whether Patten's proceeding pro se without a valid waiver of her right to counsel constituted reversible error.
2. Whether the trial court properly denied Patten's request for appointed counsel based solely on her ownership interest in real estate.

Disposition

reversed