Bowers v. State
Bowers v. State
Opinion of the Court
Maurice Bowers appeals his convictions for armed robbery with a firearm and battery, contending the trial court failed to conduct an adequate hearing as required by Faretta v. California, 422 U.S. 806, 95 S.Ct. 2525, 45 L.Ed.2d 562 (1975) and Florida Rule of Criminal Procedure 3.111(d)(2) before allowing him to represent himself at trial. We agree and reverse.
A few months after a presiding judge conducted a hearing pursuant to Nelson v. State, 274 So.2d 256 (Fla. 4th DCA 1973), and concluded that appellant’s counsel was providing effective representation, appel
In light of the consequences of a trial judge’s failure to comply with this rule [Florida Rule of Criminal Procedure 8.111(d) ] — as reflected by the large number of reported reversal of convictions resulting from noncompliance — trial judges should be particularly attuned to the requirements of this rule. Prosecutors provide valuable assistance to trial judges and to the criminal justice process generally by reminding trial judges of these requirements when appropriate. (emphasis supplied).
Michael E. Allen, Florida Criminal Procedure, § 8:9 (2012 ed.).
REVERSED and REMANDED.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.