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Request for Counsel

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: Request for Counsel

Joseph 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. The appeals court concludes that DeFilippo waived his right to counsel before trial and that he later forfeited his right to counsel through his manipulative and disruptive conduct.


Decided 05/09/23

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