People v. Harris CA4/3, G052827

Late-night incident: Erica Turner suffered a deep stab/cutting wound to her neck during an altercation after agreeing to return clothing to Brian Harris.
Witnesses and victim described Harris producing a knife, slashing/stabbing Turner, and making threats; victim tried to kick the knife away.
Harris was charged with attempted murder (count 1) and aggravated assault (count 2); enhancements and prior conviction/prior prison-term allegations were pleaded.
Harris moved to represent himself (Faretta); the trial court denied the motion after concluding his Faretta waiver form and responses showed he did not knowingly and intelligently waive counsel.
Harris pleaded guilty to aggravated assault (count 2), admitted the great bodily injury allegation and priors in exchange for a 10-year sentence; plea accepted by the court.
On appeal counsel filed a Wende/Anders brief, raised potential issues (Faretta denial, plausible self-defense, effectiveness of counsel); the court conducted independent review and affirmed the judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred in denying Harris’s Faretta motion	The court properly found the Faretta form and Harris’s answers showed he had not made a knowing, intelligent waiver	Harris argued (via appellate counsel’s suggestions) that he should have been permitted to represent himself	Denial affirmed: record showed inconsistency and the court reasonably concluded waiver was not knowing and intelligent
Whether Harris had a plausible self-defense or ineffective-assistance claim	Prosecution: record shows an unprovoked attack; plea had factual basis and produced a favorable negotiated outcome	Harris (via counsel) suggested self-defense and ineffective assistance might be arguable	No arguable claim: record lacks facts supporting self-defense; no showing counsel was ineffective or that Harris was prejudiced by counsel given plea benefits

Faretta v. California, 422 U.S. 806 (constitutional right to self-representation subject to a knowing and intelligent waiver)
Anders v. California, 386 U.S. 738 (procedures for counsel to withdraw when no meritorious appellate issues exist)
People v. Wende, 25 Cal.3d 436 (procedures for independent appellate review when appointed counsel files a no-issue brief)
People v. Kelly, 40 Cal.4th 106 (court must address any issues raised by defendant in a Wende proceeding)
People v. Windham, 19 Cal.3d 121 (court must permit self-representation if waiver is voluntary and intelligent)
People v. Benavides, 35 Cal.4th 69 (standard for ineffective assistance: deficient performance and prejudice)