Lee Roy Thomas, Appellant v. the State of Texas, Appellee

Summary

The Texas Court of Criminal Appeals held that a defendant's refusal to accept his court‑appointed attorney does not constitute a waiver of the Sixth Amendment right to counsel, and therefore the trial court erred by allowing the defendant to proceed without active representation; the conviction was reversed and the case remanded. Justice ONION dissented, arguing that the defendant had effectively waived his right.