State v. Hampton
In State v. Hampton, 208 Ariz. 241, P7, 92 P.3d 871, 873 (2004), the defendant had issued credible death threats to two different appointed attorneys. Id. PP3-4.
The supreme court stated that "it might be possible to conclude Hampton's conduct is so egregious as to constitute forfeiture of his right to counsel on appeal," but chose to remand for the appointment of new appellate counsel and specifically warned Hampton of the consequences of any future misconduct. Id. PP9-10. The court ultimately "left open . . . the question of whether certain serious misconduct by a criminal defendant can result in forfeiture of the right to counsel without prior warning." Id. P11.