State v. Hall, 294 P.3d 632

Hall, employed as a pizza-delivery driver, claimed reduced hours were retaliation for complaints.
An outside discussion with Owner and Manager escalated; Owner ordered replacement and Manager intervened.
Owner was assaulted; he suffered severe injuries requiring surgery and permanent facial reconstruction.
Hall was charged with aggravated assault resulting in serious bodily injury; jury instructed on multiple offenses.
Defense argued self-defense; no self-defense instruction was requested or given; jury convicted Hall of aggravated assault (third degree).
Post-trial, Hall moved pro se for a new trial and to proceed pro se; trial court denied; Hall appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Post-trial complaints about counsel	Hall argues Pursifell/Franco governs inquiry into dissatisfaction with counsel.	State contends Franco controls since complaints raised post-trial; no inquiry required.	Franco applies; no inquiry required; remedy lies in appellate review of trial counsel effectiveness.
Self-defense jury instruction	Hall contends the court erred by not giving self-defense instruction (plain error or ineffective assistance).	State argues proper evidence did not support a self-defense instruction and verdict would be the same.	Absence of instruction was harmless; no reasonable probability of different outcome.
Waiver of counsel and pro se motion timing	Hall claims court failed to obtain knowing waiver before pro se move post-sentencing.	State argues defendant was represented at trial and sentencing; motion did not require waiver.	No requirement to obtain waiver; error, if any, was harmless.

State v. Dunn, 850 P.2d 1201 (Utah 1993) (plain error harm standard for reviewing trial error)
State v. Templin, 805 P.2d 182 (Utah 1990) (standards for reviewing ineffective assistance claims)
State v. Pursifell, 746 P.2d 270 (Utah Ct. App. 1987) (duty to inquire into defendant's dissatisfaction with counsel)
Franco, 283 P.3d 1004 (Utah Ct. App. 2012) (post-trial complaints about counsel handled as appeal of effectiveness)
State v. Low, 2008 UT 58, 192 P.3d 867 (Utah) (jury instruction when evidence supports defense)
State v. Knoll, 712 P.2d 211 (Utah) (standard for instructing on defenses)
State v. Soules, 286 P.3d 25 (Utah Ct. App. 2012) (preserving issue when no objection to jury instruction)
State v. Hassan, 2004 UT 99, 108 P.3d 695 (Utah) (Faretta-type right to self-representation)
State v. Pedockie, 2006 UT 28, 137 P.3d 716 (Utah) (waiver of counsel and self-representation safeguards)
Bailey v. Bayles, 2002 UT 58, 52 P.3d 1158 (Utah) (harmful error standard may affirm on alternative grounds)