Frankie L. Williams v. State of Mississippi, 296 So.3d 711

Frankie L. Williams was indicted for murder and felon-in-possession; a jury convicted him of both counts and the court sentenced him to life plus ten years (concurrent).
Pretrial: defense sought and obtained mental evaluations; court found Williams competent to stand trial but did not evaluate competence to waive counsel.
On the first day of trial defense counsel (out of Williams’s presence) told the court Williams wanted to "fire counsel." The court refused to allow self-representation, stating Williams was not qualified and ordered appointed counsel to proceed.
In Williams’s presence the court explained that any questions Williams wanted would be asked through his attorneys; Williams voiced dissatisfaction with one appointed attorney but never clearly invoked a desire to proceed pro se on the record.
At trial multiple eyewitnesses identified Williams as the shooter; State introduced a sentencing order to prove Williams’s prior felony for the felon-in-possession element; defendant did not testify and offered no defense evidence.
On appeal Williams argued (1) the court violated his Faretta right to self-representation and (2) his trial counsel was ineffective for not stipulating to the prior felony; the Court of Appeals affirmed on the self-representation issue and dismissed the ineffective-assistance claim without prejudice to PCR.

Issue	Plaintiff's Argument (Williams)	Defendant's Argument (State)	Held
Right to self-representation	Williams asserts he sought to fire counsel and represent himself at trial; court should have conducted a Faretta colloquy and allowed self-representation	Court had discretion because Williams never clearly and expressly waived counsel on the record; prior competency findings and disruptive, incoherent pro se filings justified denying self-representation	Affirmed: Williams did not clearly invoke right to self-representation; even if he had, court permissibly denied Faretta under Armstead/Edwards due to mental/expressive incompetence
Ineffective assistance for not stipulating to prior felony	Counsel should have stipulated to the prior conviction to avoid prejudicial evidence; failure was deficient and prejudicial	Decision not to stipulate can be reasonable trial strategy; record insufficient on direct appeal to evaluate counsel’s strategy/prejudice	Dismissed without prejudice to raise in post-conviction relief; record inadequate on direct appeal to resolve Strickland claim

Faretta v. California, 422 U.S. 806 (1975) (defendant has constitutional right to waive counsel and represent himself)
Indiana v. Edwards, 554 U.S. 164 (2008) (States may require a higher competency standard for self-representation than for standing trial)
Armstead v. State, 716 So. 2d 576 (Miss. 1998) (recognizes exceptions permitting courts to deny self-representation when defendant is disruptive or mentally incompetent to proceed pro se)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance: deficient performance and prejudice)
Coleman v. State, 914 So. 2d 1254 (Miss. Ct. App. 2005) (discusses limits and exceptions on Faretta waiver under Mississippi law)
Hearn v. State, 3 So. 3d 722 (Miss. 2008) (addresses competency and self-representation standards)
Collins v. State, 221 So. 3d 366 (Miss. Ct. App. 2016) (declines ineffective-assistance claim where choice not to stipulate to prior felony can be reasonable strategy)
Williams v. State, 991 So. 2d 593 (Miss. 2008) (discusses when stipulation to prior convictions should be accepted and limiting-instruction requirements)