Raulerson v. Wainwright, Secretary, Florida Department of Corrections

How later courts describe this case

• "A defendant may waive his right of self-representation by electing to act as co-counsel. See Brown v. Wainwright, 665 F.2d 607, 611 (5th Cir.1982); Chapman v. United States, 553 F.2d 886, 893, n. 12 (5th Cir.1977)."
• counsel not ineffective where, although he filed no change of venue motion, he did explore the possibility of seeking a change in venue, but after the voir dire examination, he determined that such action would be fruitless
• “The Hickenlooper exception to the act of state doctrine does not apply to confiscations by a foreign state of the property of its own nationals within its border, since such confiscations are ‘not contrary to international law.’ [citation omitted]”
• request for self-representation must be unambiguous