Thanks for visiting! Welcome to a new way to research case law. You are viewing a free summary from Descrybe.ai. For citation and good law / bad law checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.
Bruce McGregor Davis, and v. Paul J. Morris, Warden, And
Citations: 719 F.2d 324; 1983 U.S. App. LEXIS 15757Docket: 82-5569
Court: Court of Appeals for the Ninth Circuit; October 28, 1983; Federal Appellate Court
Bruce McGregor Davis appealed the denial of his habeas corpus petition concerning his right to self-representation during his 1972 murder trial in California. The Ninth Circuit previously examined this issue in Davis v. Morris, noting the trial judge's concerns regarding Davis' competency to represent himself and the potential for courtroom disruption, particularly due to his association with Charles Manson and the Manson family. The district court had emphasized these factors when denying the writ. Upon remand, the California trial judge elaborated on his decision regarding Davis' self-representation request, highlighting the coordinated and disruptive behavior of Manson and his followers. He expressed doubt about Davis' ability to make an independent and informed waiver of counsel, ultimately reaffirming that the context of the trial and Davis’ connections to Manson justified the denial of self-representation. After reviewing the transcript of the remand proceedings, the Ninth Circuit found no prejudice against Davis and concluded that the trial judge's concerns were justified under both pre- and post-Faretta legal standards. The court affirmed the denial of the writ based on the factual circumstances surrounding the case. After Davis' case was separated from Manson and Atkins, the court affirmed that prior stipulations from the joined proceedings would apply to pretrial motions. Davis' counsel sought to incorporate earlier proceedings, including a motion to quash the petit jury venire, along with the evidence and stipulations from that trial. Notably, no specific motion for self-representation was reasserted at this juncture. The trial judge indicated that a motion for self-representation would not have been considered based on the existing record, which failed to present any new circumstances that would warrant reconsideration of the denial of such a motion. Therefore, Davis could not claim he was improperly denied self-representation post-severance. The court praised the quality of Davis' legal representation throughout the case and affirmed the denial of the writ of habeas corpus, concluding that all findings were supported by the trial judge's testimony, the district judge's review, and the court's own assessment of the record.