Court of Criminal Appeals of Texas

Larry Goffney, Appellant v. the State of Texas, Appellee

December 16, 19921992 Tex. Crim. App. LEXIS 235

Summary

The Court of Criminal Appeals affirmed the Court of Appeals' reversal of Goffney's conviction, holding that the trial record lacked the required admonishments about the dangers of self‑representation under Faretta and that the presumption of regularity does not apply to a waiver of counsel. The majority required a more explicit record to show an intelligent and knowing waiver. A dissent argued the existing judgment language was sufficient.