State of Tennessee v. Michael W. Parsons, 2011 Tenn. Crim. App. LEXIS 922

Parsons was convicted by a jury of two counts of aggravated assault, one count of burglary of a vehicle, and two counts of theft under $500, with felonies ordered to run consecutively for an effective seven-year sentence.
Pretrial, Parsons sought to proceed pro se with elbow counsel; later demanded full representation and continuances, leading to multiple attorney appointments and withdrawals.
Parsons ultimately represented himself at trial with advisory (elbow) counsel after a series of conflicts among appointed lawyers.
The trial included recordings of the citizen’s arrest encounter and disputes over self-defense and citizen’s arrest defenses; jurors acquitted some charges and a mistrial was declared on others.
Post-trial, Parsons challenged the trial court on right-to-counsel issues, evidentiary rulings, juror issues, sufficiency of the evidence, and sentencing, with the appellate court affirming the judgments.
The court held Parsons forfeited his right to counsel due to egregious manipulation of the process, and affirmed without relief on the remaining issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Waiver of right to counsel validity	Parsons did not knowingly waive counsel; trial court failed to properly advise.	Parsons asserted right to counsel; waiver was invalid.	Trial court erred in accepting waiver of counsel.
Forfeiture of right to counsel	Parsons abused the process to delay trial and undermine counsel.	Not applicable; conduct was not egregious.	Parsons forfeited his right to counsel due to egregious misconduct.
Evidentiary rulings at trial	Rulings prevented defendant from presenting defense.	Rulings were improper and prejudicial.	No reversible error; rulings were within discretion and harmless.
Juror issue and potential taint	Juror relationship with arresting officer tainted proceedings.	Mistrial should have been granted due to taint.	Issue without merit; juror was excused and no prejudice shown.
Sufficiency of the evidence and defenses	Evidence supported convictions; defenses rejected by jury.	Self-defense and citizen’s arrest defense not properly weighed.	Evidence sufficient; defense theories rejected; convictions affirmed.

State v. Northington, 667 S.W.2d 57 (Tenn. 1984) (requirements for valid waiver of counsel; thorough canvassing)
State v. Carruthers, 35 S.W.3d 516 (Tenn. 2000) (right to counsel; indigent defendant not entitled to counsel of choice; forfeit possible)
State v. Holmes, 302 S.W.3d 831 (Tenn. 2010) (forfeiture standard; egregious manipulation can trigger forfeiture)
State v. Hester, 324 S.W.3d 1 (Tenn. 2010) (mixed question of fact and law; de novo review with fact-finding presumption; structural error if counsel deprived)
Faretta v. California, 422 U.S. 806 (U.S. 1975) (right to self-representation; must be knowingly, intelligently waived)