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Delaware Supreme Court Reverses Escape Conviction

In December 2012, the Delaware Supreme Court reversed an escape conviction because the prisoner’s request to represent himself was improperly denied.

While serving a sentence for robbery at the Plummer Center in Wilmington, Delaware, prisoner Maurice Williams requested and received a medical pass to leave the grounds. When he did not return as scheduled, he was charged with escape.

Williams was later caught in Maryland.

During his subsequent trial, Williams, moved to represent himself. The trial judge summarily denied the request, saying “You don’t get to change your mind in the middle of the trial.”

On appeal, the Delaware Supreme Court noted that though the right to self-representation is not absolute, it cannot be denied merely because trial has commenced; rather, the trial judge considering such a motion must balance the legitimate interests of the defendant, on the one hand, against the prejudice from the potential disruption of the proceedings on the other hand.

Because the trial judge failed to engage in the required legal analysis, the Supreme Court reversed Williams’ conviction. See Williams v. State, No. 35, 2012 D, (Del. 2012).

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Related legal case

Williams v. State