Billy Ray Waldon was convicted of many serious felonies, including three counts of first degree murder, and was sentenced to death in February 1992. Today, in People v. Waldon, the Supreme Court reverses Waldon’s conviction and death sentence “[b]ecause of errors in granting Waldon’s request to represent himself.”
According to the court’s unanimous opinion by Justice Goodwin Liu, Waldon defended himself by claiming “federal agents framed him for the charged crimes to thwart his efforts to promote world peace, spread new languages, and advance Cherokee autonomy.”
One judge granted Waldon’s Faretta motion to represent himself a year after a different judge had denied a first motion and had found, as described by the Supreme Court, “Waldon had a mental disorder that prevented him from rationally perceiving his circumstances, appreciating the risks and consequences of self-representation, and appropriately formulating and presenting a defense.” Today’s opinion says that, because the second judge didn’t consider the first judge’s “denial or the evidence on which it was based,” the second judge’s ruling “was an abuse of discretion that deprived Waldon of the assistance of counsel throughout his criminal trial.”
The second judge, acceding to Waldon’s request to not review material from the first motion, said, “ ‘I have — I hate to say this on the record, but — intentionally kept myself ignorant of the history of this case.’ ” The Supreme Court says, however, “Despite Waldon urging the trial court to ignore the prior competency and Faretta proceedings, the court had a duty to protect Waldon’s right to counsel and to ‘satisfy itself that the waiver of his constitutional rights [was] knowing and voluntary.’ ”
Perhaps of broadest precedential effect — for both civil and criminal cases — is this holding: noting that “[t]here are limits . . . on the authority of one superior court judge to set aside the order of another judge of the same court,” the opinion says, “When a trial court exercises its authority to reconsider another judge’s ruling, the trial court must, at minimum, consider the basis for the prior ruling.”
Despite briefing on numerous issues that covered more than 1,500 pages, the court decides the appeal in a 32-page opinion.