State of Louisiana v. Joshua A. LeBeuf

STATE OF LOUISIANA NO. 2026 KW 0849

VERSUS

JOSHUA A. LEBEUF SEPTEMBER 18, 2026

In Re: Joshua A. Lebeuf, applying for supervisory writs, 20th
Judicial District Court, Parish of East Feliciana, Nos.
2025 - CR - 642, 643, 644, 645, 646.

BEFORE: PENZATO, LANIER, AND FIELDS, JJ.

WRIT GRANTED IN PART AND DENIED IN PART. An accused' s

technical legal knowledge, as such, [ is] not relevant to an

assessment of his knowing exercise of the right to defend himself."
See Faretta v. California, 422 U. S. 806, 836, 95 S. Ct. 2525, 2541,
45 L. Ed. 2d 562 ( 1975). A trial judge confronted with an accused' s
unequivocal request to represent himself need determine only
whether the accused is competent to waive counsel and is
voluntarily exercising his informed free will. State v. Santos,
99- 1897 ( La. 9/ 15/ 00), 770 So. 2d 319, 321 ( per curiam). In this
context, "
the competence that is required of a defendant seeking
to waive his right to counsel is the competence to waive the right,
not the competence to represent himself." Godinez v. Moran, 509
U. S. 389, 399, 113 S. Ct. 2680, 2687, 125 L. Ed. 2d 321 ( 1993). In

assessing whether relator was making a knowing and intelligent
request to represent himself, the record reflects that the district
court asked relator if he has some " significant legal training."
The record does not
affirmatively show that the district court

inquired into relatorfs competence to waive counsel. Accordingly,
the writ application is granted for the sole purpose of remanding
for a reopened hearing on relator' s motion for self -representation
to be conducted in accordance with Faretta. In all other respects,
the writ application is denied.

AEP
WIL
WEF