Cano v. Anchorage

In Cano v. Anchorage, 627 P.2d 660 (Alaska App. 1981) the defendant and his appointed attorney were willing to proceed as co-counsel. The trial court refused to even consider the request. The Court ruled that the trial court abused its discretion by its "outright refusal" to consider various alternatives available to it. This "amounted to nothing more than a denial by the court of its own authority." The defendant then decided to proceed pro se and eventually convinced the judge to allow appointed counsel to stand by in the courtroom; the appointed counsel was unable to participate in the trial, but was available for consultation during recesses. The Court reversed the conviction. In a concurring opinion, Judge Coats pointed out that the court's ruling "was very limited" and among other things did not address situations where counsel objected to co-counsel status.