Marshall v. Rodgers

PETITIONER: John Marshall, Warden
RESPONDENT: Otis Lee Rodgers
LOCATION: Garden Estates Apartments

DOCKET NO.: 12-382
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 569 US (2013)
GRANTED: Apr 01, 2013
DECIDED: Apr 01, 2013

Facts of the case

On July 15, 2001, Otis Lee Rodgers was arrested after he threatened to shoot his wife in the head outside of the Garden Estates Apartments in Riverside, California. Before his trial, Rodgers waived his Sixth Amendment right to counsel and chose to represent himself. Rodgers then changed his mind several times, retaining and dismissing court-appointed attorneys, until his eventual trial. A Riverside County Superior Court jury subsequently found him guilty of assault with a firearm, possession of a firearm as a felon, possession of ammunition as a felon, and making criminal threats. He also admitted that he was on bail for another pending felony trial and had two prior felony convictions. Rodgers was sentenced to sixteen years in prison.

After sentencing, Rodgers asked the court to appoint an attorney to help him file a motion for a new trial. The trial judge denied his request and subsequently denied his pro se motion for a new trial. Rodgers appealed to the U. S. District Court for the Central District of California, seeking habeus corpus relief for the judge’s refusal to appoint counsel for the motion for a new trial. That court denied his petition. Rodgers then appealed to the U.S. Court of Appeals for the Ninth Circuit. That court granted Rodgers’ petition and remanded the case for trial.

Question

Does a trial judge’s determination to deny a defendant’s request for reappointment of counsel after the defendant previously refused representation violate federal law?