Domestic Violence-Right to Counsel

By: WISCONSIN LAW JOURNAL STAFF//May 2, 2023//

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WI Court of Appeals – District III

Case Name: State of Wisconsin v. Joseph P. DeFilippo

Case No.: 2021AP001248-CR

Officials: Stark, P.J., Hruz and Donald, JJ.

Focus: Domestic Violence-Right to Counsel

DeFilippo, among other things, held down his former roommate, slapped her face, and held his forearm over her throat as she attempted to move her belongings out of DeFilippo’s home. DeFilippo appeals from a judgment, entered after a jury trial, convicting him of several offenses arising out of a domestic violence incident, and a subsequent incident with his neighbor. DeFilippo argues that he did not properly waive his right to counsel before trial and that the circuit court erred by denying his request—first made after jury selection—to obtain counsel. DeFilippo waived his right to counsel before trial and he later forfeited his right to counsel through his manipulative and disruptive conduct, the appeals court ruled.

Affirmed.

Decided 04/25/23

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