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Fourth Department – Request to proceed pro se: People v. Love
Daily Record Staff//May 11, 2026//
New York State Supreme Court, Appellate Division, Fourth Judicial Department
Request to proceed pro se — Leveraging a new lawyer — Unequivocal request
KA 23-01812
Appealed from Monroe County Court
Background: The defendant appealed from his conviction of grand larceny. He argues that the court erred in denying his request to proceed pro se.
Ruling: The Appellate Division affirmed. The court held that the defendant did not unequivocally request to proceed pro se. He asked to proceed pro se only as an alternative to receiving new counsel, thereby seeking to leverage his right of self-representation in an attempt to compel the court to appoint another lawyer.
Stephanie M. Stare, of the conflict defender’s office, for the defendant-appellant; Aeron Schwallie, of the district attorney’s office, for the respondent.
Submitted
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- Fourth Department – Dismissal of the indictment: People v. Anderson
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