Trujillo v. State (2000)
In Trujillo v. State, 2 P.3d 567, 573-75 (Wyo. 2000), the defendant repeatedly interfered with his court-appointed counsel's ability to represent him.
Trujillo ultimately went through four attorneys. Understandably frustrated, the district court elected to proceed with sentencing without appointing a fifth attorney. Thus, Trujillo was sentenced without any legal representation.
The Court concluded that a defendant's actions could be so dilatory and obstructive that he could be deemed to have waived his right to legal representation.
However, in order for that waiver to be knowing and voluntary, we required the trial court to warn the defendant that his continued misbehavior would result in a waiver of that right. Trujillo, 2 P.3d at 572-75.