Defendant Denied Pro Se Status Has Robbery Convictions, 50-Year-to-Life Sentence Reversed
"While giving lip service to defendant's right to represent himself, the [lower] court nonetheless foisted counsel on defendant over defendant's vigorous protests," wrote state appeals court Justice Sallie Manzanet-Daniels on behalf of a unanimous four-judge panel.
April 03, 2020 at 12:12 PM
6 minute read
For some two years, before multiple judges, and while having at least five different lawyers appointed to represent him as he faced major robbery charges, Reginald Trammell kept insisting to a trial court that he wanted to represent himself pro se, according to a state appeals court decision issued Thursday.
His requests were consistently pushed aside; he was never given that right.
At one point, in 2008, one trial judge told him that representing himself was "a very dangerous thing"—and then the judge urged him to work with his lawyer, putting off Trammell's request, according to Thursday's decision.
In 2009 and 2010, a second judge variously ordered examinations of Trammell's mental competency to understand the proceedings against him—Trammel passed each time—essentially ignored his self-representation requests while giving them "lip service," according to the decision, and decided that Trammell was trying to "disrupt" the proceedings and subvert the judicial process.
Now, the Appellate Division, First Department, in a long and factually detailed opinion written by Justice Sallie Manzanet-Daniels, has reversed the 2011 jury trial conviction of Trammell on five robbery charges, along with his aggregate prison term of 50 years to life, which he was given, in part, because he was "a persistent violent felony offender," according to the First Department's decision.
And the appellate panel has ordered a new trial.
In an opinion that was critical of the handling of the case below, especially in its last 10 or so paragraphs, Manzanet-Daniels wrote in part, "While giving lip service to defendant's right to represent himself, the [lower] court nonetheless foisted counsel on defendant over defendant's vigorous protests."
"As [People v.] Schoolfield, counsels," the justice wrote, "a court may not foist an attorney on defendant simply because it feels a defendant is better served by assigned counsel (196 AD2d at 115) … That he might be better served by counsel is immaterial."
Manzanet-Daniels also made clear, early in the opinion, the clear U.S. constitutional and New York state constitutional right that a criminal defendant has to act as their own counsel.
"The right of self-representation is a fundamental right guaranteed both by the [U.S. Constitution's] Sixth Amendment and article 1, § 6 of the New York State Constitution," wrote Manzanet-Daniels, "and 'forcing a lawyer' on a defendant is contrary to this basic right," quoting People v. Lewis.
"When a defendant desires to exercise the right to represent himself, 'the court's only function is to ensure that the defendant is acting knowingly and voluntarily, that is, that the defendant is aware of the disadvantages and risks of waiving his right to counsel,'" Manzanet-Daniels continued, again quoting Schoolfield.
Then she added, quoting Schoolfield, "Respect for individual autonomy requires that he [the defendant] be allowed to go to jail under his own banner if he so desires and if he makes the choice with eyes open."
The First Department's decision found to be erroneous self-representation request rulings made by both Manhattan Supreme Court Justices Richard Carruthers and Ruth Pickholz—though, according to the opinion, the bulk of the rulings were made by Carruthers.
The opinion reversed Trammell's conviction on three first-degree counts of robbery and two third-degree robbery counts, and it vacated his sentence.
Manzanet-Daniels was joined by First Department Justices Barbara Kapnick, Ellen Gesmer and Jeffrey Oing.
In a detailed factual recitation in the 15-page opinion, Manzanet-Daniels laid out how Trammell, time and again, made it unequivocally clear to lower court justices that he wanted to represent himself, and how, for Justice Carruthers, at least, there was a serious question about whether Trammell was mentally sound.
At one point, according to the opinion, in 2009, Trammell said in court to Carruthers that he wanted to "state in the record [that] for more than a year I have been attempting to assert my right to proceed [pro] se" and "every time I do that I am put in for a 730 [mental defect] evaluation and reassigned another attorney. The Court record will bear out this happened three times."
Moreover, said Trammel, according to the opinion, "every time the Court has put me in for a 730 and reassigned me counsel as though the basis of my argument was really a request for reassignment of counsel."
Manzanet-Daniels wrote that, in response, Carruthers "explained [to Trammell] that he hadn't ordered 730 exams because defendant [Trammell] wanted to represent himself, but because defendant appeared to have a 'mental issue' that would make it difficult for him to represent himself." But Carruthers responded that way, wrote Manzanet-Daniels—while using parentheses—"despite the fact that defendant had already been found fit to stand trial."
Later in the opinion, Manzanet-Daniels wrote, "If the court believed that defendant was trying to subvert the trial, it was obliged to conduct the 'dispassionate inquiry' required by [People v.] McIntyre to ascertain whether defendant's requests were calculated to delay and disrupt or were a good faith attempt to exercise his constitutional right to represent himself."
The justice continued, "Instead of conducting the requisite inquiry, the court ordered 730 examinations and assigned successive defense counsel, notwithstanding defendant's legitimate complaints about [one] counsel's deficiencies. It was acknowledged that [the particular] counsel filed an incorrect motion on defendant's behalf and that a corrected motion was never filed, belying the notion that defendant's request was calculated to disrupt."
Andrew Fine, a criminal appeals bureau attorney at the Legal Aid Society of New York, who helped represent Trammell in the appeal, said in an email Thursday that "we are extremely pleased by the [First Department's] decision."
"Mr. Trammell repeatedly requested to represent himself over a period of more than two years," Fine wrote, and "those requests were not granted; instead, new lawyers were appointed, the court ordered hearings to determine whether he was competent which were resolved in his favor, and twice judges agreed to allow him to represent himself but never took the steps necessary to allow him to do so."
"The [U.S.] Supreme Court has recognized for decades that the right of self-representation is constitutionally protected," he added.
Trammell, who was listed in the First Department decision as also being an appellate counsel pro se, could not be reached.
The Manhattan District Attorney's Office, which represented the State of New York in the appeal, declined to comment.
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