Willie Lee Hudson v. Ruth L. Rushen, Director of the California Department of Corrections

Willie Lee Hudson, a California state prisoner, petitioned for a writ of habeas corpus alleging that the state trial court violated his right to effective assistance of counsel as guaranteed by the Sixth Amendment to the United States Constitution by failing to inquire adequately into his reasons for moving to substitute counsel. The district court granted the petition. The State of California (“the State”) appealed. We hold that, inasmuch as the state trial court’s inquiry into the petitioner’s dissatisfaction with his counsel, though brief, was sufficient under the circumstances to constitute “an adequate and fair hearing on [defendant’s] motion,” United States v. Mills, 597 F.2d 693, 700 (9th Cir. 1979), the petitioner received effective assistance of counsel. We reverse the grant of the writ of habeas corpus.

FACTS

Petitioner Hudson was convicted after jury trial in San Francisco Superior Court of kidnapping, forcible rape, and forcible oral copulation, all committed while armed with a deadly weapon. He was also convicted of assault by means of force likely to produce great bodily injury, battery against a police officer, and resisting arrest. The California, Court of Appeal…