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Second Circuit Review: Sixth Amendment Right to Counsel

January 28, 2008 Full PDF

Litigation partners Marty Flumenbaum and Brad Karp's "Second Circuit Review" column appeared in the January 28 issue of the New York Law Journal. The article, "Sixth Amendment Right to Counsel," discusses the case of Clark v. Perez in which a panel of judges reversed a district court judgment granting a habeas petition and ordering a new trial for prisoner Judith Clark. The article analyzes Ms. Clark's case and her recent appeals where she claimed her Sixth Amendment rights were violated. It was ultimately determined that her rights were not violated as she adamantly refused counsel, was disruptive in court, was often absent and insisted on proceeding pro se in the original trial in adherence to her political beliefs. Litigation associate Colin McNary assisted in the preparation of the column.

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