Adrian Jackson v. State of Indiana
992 N.E.2d 926
| Ind. Ct. App. | 2013Background
- On March 7, 2012, three masked, armed men robbed Oriental Market, confined and assaulted employees and patrons, and stole cash, phones, keys, and other property; eyewitnesses identified Adrian Jackson at the scene.
- Police arrested Jackson near the getaway vehicle; items from the robbery and a firearm with Jackson’s DNA were recovered; Jackson had cash on him at arrest.
- The State charged Jackson with multiple counts (criminal confinement, robbery, battery); a public defender (Josh Moudy) was appointed after Jackson was found indigent.
- One month before trial Jackson told the court he wanted to proceed pro se, alleging his appointed counsel was "working for the State." The court conducted an advisement colloquy, warned him of disadvantages, accepted his signed written waiver, and appointed standby counsel.
- A jury convicted Jackson on seven counts (one later dismissed); sentences were merged and ordered largely consecutive for an aggregate 30-year term. Jackson appealed, arguing the court erred by not inquiring into/appointing substitute counsel for an alleged conflict and that his waiver of counsel was not knowing, voluntary, and intelligent.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Jackson) | Held |
|---|---|---|---|
| Whether the trial court had a duty to inquire into an alleged conflict of interest of appointed counsel | No affirmative duty here; presumption of competence; court reasonably relied on Jackson’s failure to present specific proof | Trial court should have investigated and appointed substitute counsel or at least inquired further because Jackson alleged counsel was "working for the State" | Court held no duty to further inquire or appoint substitute counsel because Jackson offered only vague, unsupported accusations and did not request substitute counsel; presumption of competence stands |
| Whether Jackson’s waiver of counsel was knowing, voluntary, and intelligent | The colloquy, written waiver, standby counsel, and Jackson’s background satisfied Poynter factors; waiver was valid | Waiver was involuntary/coerced because Jackson felt compelled to choose self-representation after court refused substitute counsel for alleged conflict | Court held waiver valid: trial judge gave thorough warnings, elicited understanding, noted Jackson’s experience, and Jackson freely persisted in his choice |
Key Cases Cited
- Smith v. State, 474 N.E.2d 973 (Ind. 1985) (appointment of counsel to indigent defendants subject to trial court discretion)
- Irvin v. State, 291 N.E.2d 70 (Ind. 1973) (presumption of competence for appointed counsel; defendant may refuse appointed counsel and must obtain other counsel or proceed pro se)
- Johnson v. State, 948 N.E.2d 331 (Ind. 2011) (Sixth Amendment generally does not impose duty to inquire into conflict claims absent a showing)
- Holloway v. Arkansas, 435 U.S. 475 (1978) (conflict-of-interest rule triggered when counsel represents multiple defendants with potentially adverse interests)
- Cuyler v. Sullivan, 446 U.S. 335 (1980) (establishes standard for proving adverse effect from joint representation in order to require reversal)
- Poynter v. State, 749 N.E.2d 1122 (Ind. 2001) (four-factor framework for evaluating whether waiver of counsel is knowing, voluntary, and intelligent)