38 Wake Forest L. Rev. 55 (2003)
Hybrid Representation: Standing the Two - Sided Coin on its Edge

handle is hein.journals/wflr38 and id is 65 raw text is: HYBRID REPRESENTATION:
STANDING THE TWO-SIDED COIN ON ITS EDGE
Joseph A Colquitt*
Despite its potential benefits, hybrid representation is neither
required by law nor favored by courts. While this Article both
accepts and reinforces the premise that federal and state
constitutional law as presently interpreted does not require
courts to provide or permit hybrid assistance of counsel, Judge
Colquitt argues that American courts should retreat from their
disfavor of and, in fact, embrace the use of hybrid assistance of
counsel in appropriate cases.
The right to counsel and the right to defend pro se in criminal
cases form a single, inseparable bundle of rights, two fases [sic]
of the same coin.'
I.   INTRODUCTION
In the popular action movie Red Corner,' Jack Moore, an
American, is accused of murder while on a business trip to the
People's Republic of China. Before and during the trial in a People's
Court, Moore and his appointed defense counsel, Advocate Yuelin,
argue about strategy and tactics. Their dispute flares during the
following scene from the trial:
* Jere L. Beasley Professor of Law, University of Alabama School of Law;
retired circuit judge, Sixth Judicial Circuit, State of Alabama. I thank the
University of Alabama Law School Foundation for its generous support. I am
particularly indebted to Dean Kenneth Randall and Professors William S.
Brewbaker, III, Pamela H. Bucy, and Norman P. Stein for their interest,
encouragement, and suggestions. Brent Woodall, John C.H. Miller, III, Kacey
Keeton, Jaime Cowley, and Elizabeth Butler provided valuable research
assistance. Naturally, I alone remain responsible for any errors.
1. United States v. Plattner, 330 F.2d 271, 276 (2d Cir. 1964).
2. RED CORNER (Metro-Goldwyn-Mayer Pictures, Inc. 1997). Richard Gere
starred as the accused, Jack Moore; Ling Bai played Shen Yuelin, the advocate.
Id.

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