Schaeffer v. State
2012 WY 9
| Wyo. | 2012Background
- Appellant Schaef-fer convicted of one count of aggravated assault and battery for waving a flare gun during a bar altercation.
- On the second day of trial the court considered Schaef-fer's complaint letter about his attorney and whether to appoint new counsel, ultimately denying substitution.
- Schaef-fer argued he should be allowed to represent himself and/or have new counsel; the court conducted Colloquy but did not find a valid waiver of counsel.
- Throughout trial Schaef-fer was restrained with belly chain, handcuffs, and shackles due to disruptive conduct; the court addressed security concerns and alternatives.
- The court later addressed competency; a prior evaluation found competence with noted behavioral risks, and no new evaluation was ordered absent reasonable cause.
- Schaef-fer challenged several trial rulings and sentence-related information; the court affirmed, finding no plain error or bias and that the evidence supported the conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion in not appointing substitute counsel | Schaef-fer argued good cause existed due to counsel's incompetence and conflicts | Schaef-fer claimed dissatisfaction warranted substitution | No abuse; no good cause shown; substitution not required |
| Whether Schaef-fer validly waived the right to counsel and proceeding pro se | Schaef-fer claimed he sought self-representation | No unequivocal request to proceed pro se; he wanted new counsel | No valid waiver; trial court did not err in denying self-representation |
| Whether excessive restraints were used against Schaef-fer during trial | Restraints were overly punitive and prejudicial | Court exercised discretion; restraints necessary due to conduct | No reversible error; court's restraints were within its discretion under the circumstances |
| Whether the district court should have ordered a further competency evaluation | Additional competency evaluation was required given concerns | Record supported continued competence | No error; substantial evidence supported continuing with the original competency finding |
| Whether there was plain error in not instructing the jury to disregard shackles observed by the jury | Jury voir dire/charges should have included instruction to disregard shackles | No plain error; warning and record showed awareness of potential prejudice | No plain error; no prejudice to substantial rights demonstrated |
| Optional additional issue retained for clarity (competency, new motions) | N/A | N/A | N/A |
Key Cases Cited
- Allen v. State, 43 P.3d 551 (Wyo.2002) (duty to inquire about substitution; prejudice required for error to be reversible)
- Bell v. State, 994 P.2d 947 (Wyo.2000) (Sixth Amendment right to counsel; focus on adversarial process)
- Asch v. State, 62 P.3d 945 (Wyo.2003) (shackling in presence of jury; framework for review of restraints)
- Urbigkit v. State, 67 P.3d 1207 (Wyo.2003) (restraint review; consideration of alternatives and officer recommendations)
- Van Riper v. State, 882 P.2d 230 (Wyo.1994) (necessity and voluntariness of waiver inquiry; standards for waiver)