State v. Jackson, 867 N.W.2d 814

Andrew L. Jackson was charged in consolidated Milwaukee County cases with multiple violent offenses (including first‑degree reckless injury and aggravated battery) and four counts of witness intimidation; he ultimately pled guilty to four felonies and received an aggregate 31‑year sentence.
Jackson repeatedly complained about appointed counsel, restricted phone/mail access (due to intimidation charges), and requested either new counsel or to represent himself at various pretrial hearings.
The trial court warned Jackson about the complexity of the case (eight charges, multiple events, complex legal issues) and repeatedly asked him to demonstrate preparedness (witness list, voir dire questions, opening statement); Jackson failed to do so.
After colloquies in which Jackson showed limited understanding of pending motions and trial law, the trial court found his requests "episodic driven," concluded he had not validly waived counsel, and found him incompetent to proceed pro se.
Jackson filed postconviction motions to withdraw his pleas, arguing he was denied the right to self‑representation and that Wisconsin's Klessig competency standard conflicted with Indiana v. Edwards; motions were denied and he appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Wisconsin's Klessig standard for competency to proceed pro se is unconstitutional under Edwards	Klessig improperly allows denial of self‑representation beyond the "severely mentally ill" standard described in Edwards	Klessig's waiver/competency colloquy and presumption of nonwaiver are consistent with Edwards and permissible	Klessig standard is constitutional and not inconsistent with Edwards; affirming trial court
Whether Jackson validly waived his right to counsel	Jackson argues his pleas were not knowing/voluntary because court denied his request to represent himself	Trial court contends Jackson's requests were impulsive, rooted in dissatisfaction, and he failed to satisfy Klessig's waiver criteria	Jackson did not knowingly, intelligently, voluntarily waive counsel; waiver not established
Whether Jackson was competent to represent himself	Jackson asserts he was ready to proceed pro se despite communication limits	Trial court found Jackson lacked understanding of legal issues and trial complexity and was unprepared	Trial court reasonably found Jackson not competent to proceed pro se
Whether postconviction relief (withdraw plea) was required by the alleged denial of Faretta rights	Jackson seeks withdrawal based on denial of self‑representation right	State argues no Faretta violation; colloquy and competency findings adequate	No reversible error; postconviction relief denied

Faretta v. California, 422 U.S. 806 (recognition of Sixth Amendment right to self‑representation)
Indiana v. Edwards, 554 U.S. 164 (States may require counsel for defendants with mental illness who lack capacity to conduct trial proceedings)
State v. Klessig, 211 Wis. 2d 194 (Wisconsin waiver/colloquy requirements for valid self‑representation)
State v. Imani, 326 Wis. 2d 179 (2010) (procedural standards: must ensure waiver is knowing, intelligent, voluntary and defendant is competent pro se)
State v. Darby, 317 Wis. 2d 478 (clarifies requirement for a clear and unequivocal request to proceed pro se)
Pickens v. State, 96 Wis. 2d 549 (trial court's competence determinations for pro se status are factual and afforded deference)
Cook v. Cook, 208 Wis. 2d 166 (court cannot overturn Wisconsin Supreme Court precedent)