State of Missouri, Respondent, v. Elizabeth M. Speer, Appellant.(2026)
Missouri Court of Appeals, Eastern DistrictFebruary 17, 2026#ED113172
The court reversed defendant's convictions for second-degree property damage and fourth-degree assault because the trial court failed to conduct an adequate Faretta hearing and failed to ensure a written waiver of counsel was entered prior to trial, as required by Missouri law. Although the defendant did not preserve the issue by objecting at trial, the court found the error must be reviewed because the failure to conduct a proper Faretta hearing is a constitutional violation that cannot be waived.
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