Justia Criminal Law Opinion Summaries

Appellant Clarence Dixon was convicted of first degree murder and sentenced to death. At trial, he represented himself. A jury found him guilty on all counts. When Appellant elected before trial to represent himself, the judge warned him that he would have sole responsibility for his defense, including examining and cross-examining witnesses. Appellant requested that an advisory counsel handle the examination of witnesses. The trial court rejected this proposal. On appeal, Appellant claimed multiple errors by the trial court entitled him to a new trial, including the trial courtâs denial of his proposed âhybrid representation.â The Supreme Court noted that âthere is no constitutional right to hybrid representation.â The Court found that the trial court did not abuse its discretion in denying Appellantâs motion. Finding no other errors from trial, the Court affirmed the lower courtâs decision and Appellantâs death sentence.