State v. Flatoff — Defendant Who Refuses All Appointed Attorneys Validly Waives Right to Counsel; Trial Court May Override Public Defender Rules to Appoint Standby Counsel in Extraordinary Circumstances
The Wisconsin Court of Appeals, District II, affirmed convictions for attempted homicide and felony murder, holding that Flatoff’s refusal to cooperate with seven appointed attorneys and his insistence on controlling all trial strategy constituted a valid waiver of the right to counsel under State v. Klessig; the court also upheld the trial court’s inherent authority to appoint a public defender as standby counsel despite WIS. ADMIN. CODE § PD 5.03’s prohibition, where no reasonable alternative existed and the county agreed to pay.