P. v. Adams
In an amended complaint filed in July 2009, Tyler Adams and three others were charged with numerous counts of theft and financial fraud. During the next two and one-half years, Adams obtained multiple delays of his trial because he filed a repeated series of Marsden[1]and Faretta[2] motions that created a revolving door of appointed counsel, retained counsel, and self-representation. In addition, three other delays occurred when Adams's behavior compelled the court to suspend proceedings to allow psychological exams of him under Penal Code[3] section 1368.
In the final round of representational shuffling, Adams's retained counsel asked to be relieved because Adams had defaulted on his agreement to hire essential financial experts. The court relieved retained counsel and reappointed the alternate public defender, who subsequently moved for a four-month continuance. When Adams objected and declined to waive time for trial, the court found good cause to grant the continuance over Adams's objection. However, Adams then asked to be allowed to represent himself to preserve the existing trial date and, after conducting a Faretta hearing, the court granted his request to represent himself. Several weeks later, Adams pleaded guilty to all of the charged counts and associated allegations. The court sentenced him to 14 years in prison.
On appeal, Adams claims he was coerced into waiving his right to be represented by counsel by the court's erroneous rulings, and therefore his waiver of counsel was involuntary. He claims the court erroneously refused to compel his retained counsel to continue representing him, and then erroneously refused to compel the newly reappointed alternate public defender to proceed to trial less than eight weeks after being appointed, which forced Adams into choosing between waiving his speedy trial rights (to preserve his right to counsel) or waiving his right to counsel (to preserve his speedy trial rights). We find no error, and affirm the judgment.
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