Court of Criminal Appeals of Texas

Earl Barrington Burgess, Appellant v. the State of Texas, Appellee; Paul Edward Archie, Appellant, v. the State Of…

September 18, 19911991 Tex. Crim. App. LEXIS 182

Summary

The Court affirmed the appellate courts' judgments, holding that a written waiver of the right to counsel under Texas Code of Criminal Procedure article 1.051(g) is not required when a defendant affirmatively asserts his Faretta right to self‑representation. The opinion interprets the statutory language as a guideline, not a mandatory requirement, and emphasizes the constitutional protection of self‑representation.