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State v. Outland

New Jersey Supreme Court

March 16, 2021

Justice Pierre-Louis authored her first opinion for the New Jersey Supreme Court in State v. Outland. The defendant wanted to represent himself at trial. The Law Division judge held a hearing and quizzed the defendant about substantive questions of law. The defendant failed the quiz because he could not adequately explain such matters as affirmative defenses and could not recount the substance of his studies regarding the rules of evidence. The Law Division denied the defendant’s request to represent himself, and he was convicted with counsel at his side. The Supreme Court reversed, holding that the purpose of the hearing is “to ensure that he makes his decision to waive counsel with eyes open,” and is not meant to be a bar examination.

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