Washington v. Hahn

The defendant, Harlan Henry Hahn, appeals the judgment and sentence imposed after he was convicted by a jury for second degree felony murder. He asserts that the trial court erred in finding him competent to stand trial, and competent to waive his right to plead not guilty by reason of insanity (NGI), and his right to counsel. We reverse because there is inadequate evidence of a knowing and intelligent waiver of the right to counsel.