The American right to refuse a lawyer is older than most people expect and stranger in practice than it looks on paper. A defendant who wants to speak for himself can generally do so, so long as he asks in time, understands what he is giving up and does not turn the courtroom into a stage for disruption. The Supreme Court settled the principle in 1975, in Faretta v. California, and trial judges have been working out its edges ever since. In capital cases the question is sharper still, because a judge has to decide whether a man choosing to defend himself against a death sentence is exercising a right or ending his own life by procedure.
The eleven men here were convicted murderers who made that choice at some stage, in whole or in part. They are not a single type. Some wanted to put on a defense and could not stop talking. Some wanted to be sentenced to death and said so. A few wanted to control a story, and one wanted only to be done. What the courts did with each, and what the appellate judges later said about it, shows how little certainty the law offers on the point.
Ted Bundy’s name is attached to self-representation more than any other. In 1977 he was extradited to Colorado to face a murder charge in Pitkin County, and he chose to act as his own lawyer. The Colorado case was never tried. Two years later, in Florida, he stood trial for the murders of two women in Tallahassee in January 1978 and the other charges arising from that night. The trial was moved to Miami because an impartial jury could not be seated in Leon County, and it opened on June 25, 1979, before Judge Edward Cowart, with television cameras in the courtroom. It was one of the first trials in the country to be broadcast nationally.
Bundy acted as one of his own lawyers. He questioned witnesses and made objections himself, often to the frustration of the attorneys assigned to him, and at one point spoke of himself in the third person. He was convicted and sentenced to death. In a second Florida trial, for the murder of a 12-year-old girl, he was again convicted, with other charges, and again sentenced to death. In all he was convicted of three murders in Florida.
The legal question came later and ran in the opposite direction from the usual one. After years of appeals, his lawyers argued in federal court that he had never been mentally competent to stand trial or to help in his own defense. A hearing was held in Orlando before U.S. District Judge G. Kendall Sharp in October and December 1987. Dorothy Lewis, a New York University psychiatrist, testified that Bundy suffered from bipolar mood disorder and could not have assisted counsel. Two other psychiatrists disagreed, and Judge Sharp preferred their view. He ruled that Bundy "was at all times competent to stand trial." The Eleventh Circuit affirmed in 1988, rejecting every claim in the petition. Bundy was executed in Florida on January 24, 1989.
Douglas Clark’s trial in Los Angeles in 1982 became a standard citation on how far a judge can go in policing self-representation. He was charged in 1980 with six murders. The public defender declared a conflict, and the court appointed a private lawyer. Clark asked repeatedly to serve as co-counsel in his own case, and the court refused in December 1980. By the summer of 1982 his relations with his current lawyer had collapsed. On August 13 he formally asked to represent himself. On August 20 the court denied the request as untimely, with jury selection about to begin.
On October 12 and 13, 1982, after a hearing on a waiver of counsel, the court relented and let Clark take over, keeping both of his lawyers as standby counsel. The arrangement lasted about two weeks. On November 1 Clark made a string of motions outside the jury’s presence, including one to remove the entire district attorney’s office from the case. The judge called the recusal motion frivolous and told him to stop arguing it. When the jury returned and the judge told him to go on with cross-examination, Clark announced that "the defense stands mute throughout the rest of the trial." The court treated the statement as a surrender of his self-representation, and the standby lawyers took over that afternoon.
The next day Clark reconsidered. The judge said Clark was "playing games" but restored his right to represent himself, with a warning. On December 2, 1982, Clark gave his own opening statement and told the jury he would prove that two other people were the real killers. On December 6, after what the California Supreme Court later called "a series of abusive and threatening remarks" aimed at the judge, the court revoked self-representation permanently and reappointed the standby lawyers, who handled the rest of the trial.
He was sentenced to death on March 16, 1983, on six counts of first-degree murder, with a further term for a lesser count and nine years for attempted murder. In July 1992 the California Supreme Court affirmed the murder convictions and the death judgment, reversing the attempted murder and mayhem counts and setting aside most special-circumstance findings. Much of the opinion concerned who had controlled the defense. It held that his July 1982 attempt to dismiss one lawyer was not a clear request to represent himself, that the August request was untimely, and that the judge was right to refuse a law clerk, whose help it called "merely convenient." It read the stand-mute announcement as part of a deliberate pattern of manipulation and quoted the United States Supreme Court on the point that self-representation "is not a license to abuse the dignity of the courtroom." Two justices dissented on opposite grounds. Justice Kennard thought the court had erred by not letting him stand mute. Justice Mosk thought it had erred by granting self-representation in the first place.
The federal courts took forty more years to finish with it. On October 10, 2023, a Ninth Circuit panel affirmed the denial of habeas relief, holding that the state court could reasonably have treated the July request as equivocal and the August request as late, and that a court may end self-representation for serious and obstructionist misconduct. Clark died of natural causes the next day, October 11, 2023, while held on condemned status at San Quentin.
Carroll Cole’s case is the cleanest example of a defendant using the right to remove every obstacle between himself and a death sentence. He was convicted by jury verdicts of three murders in Dallas and had earlier pleaded guilty in Missouri to assault with intent to kill. In Nevada he was charged with the first-degree murder of one woman in Las Vegas and with a second death in the state. On his lawyer’s advice he first pleaded not guilty by reason of insanity. Several psychiatrists examined him and agreed that he had been sane and competent. He then changed his plea to guilty.
His sentence was to be set by a panel of three judges. Cole insisted on representing himself at the penalty hearing. The district court questioned him at length, as Faretta requires, before allowing it. It appointed standby counsel, whom he could consult if he wished, and a separate amicus lawyer to assist the panel. Cole objected when others tried to present mitigating evidence for him, asked to be sentenced to death and filed no appeal. The panel sentenced him to death, and judgment was entered on October 12, 1984.
The Nevada Supreme Court did not let the matter rest there. It appointed counsel to brief whether Cole had validly waived his appeal, and the lawyer, Edward G. Marshall, reported by affidavit that Cole had said clearly and repeatedly that he wanted no appeal and wanted the case expedited. On October 22, 1985, in an unsigned opinion, Cole v. State, the court held that he had waived intelligently and competently. It reasoned that a defendant who pleads guilty must have at least the same right to waive review as one who goes to trial. It then reviewed the sentence anyway, as Nevada law required, and affirmed it as neither excessive nor disproportionate, pointing to the care the trial court had taken, including the appointment of amicus counsel.
Cole was executed by lethal injection at Nevada State Prison in Carson City on December 6, 1985, the first person in Nevada to die by that method. The Las Vegas Sun counted him in 2005 among the volunteers who gave up their appeals; of the eleven men executed in the state since the 1970s, ten had done so.
Delaware had not executed anyone since 1946 when Steven Pennell’s case reached its end. A jury convicted him in November 1989 of the first-degree murders of Shirley Ellis and Catherine DiMauro. He was later indicted for two more, Michelle Gordon and Kathleen Meyer. A mistrial had ended the earlier Gordon count, and the Meyer case had never been tried.
By 1991 Pennell wanted to run his own defense. At a hearing on August 20 he asked to represent himself, and the Superior Court ordered an independent psychiatric evaluation. The psychiatrist reported on September 10 that he was competent to stand trial, to represent himself and to enter a plea. On October 11 the court granted the request, ruling that he had knowingly, intelligently and voluntarily given up his right to a lawyer. It appointed standby counsel, and a separate lawyer for the limited purpose of motions about the DNA evidence. Ten days later Pennell asked to change his pleas to nolo contendere, in which a defendant does not admit guilt but does not contest the charge. The court questioned him on October 30, accepted the pleas and, after the State presented the 1989 trial record and live testimony, ruled him guilty of both murders. He waived a jury at sentencing, and the Superior Court judge imposed death sentences on October 31, 1991.
He told reporters he was innocent and wanted to die to spare his wife and two children further pain. The Delaware Supreme Court was not content to take his word for the choice. It held another hearing on December 19, 1991, and adopted the finding that his decision to act as his own lawyer was knowing and voluntary. When he asked the court to affirm without review, it refused on January 16, 1992, because the law made review mandatory, but it speeded up the schedule. On February 11, 1992, Pennell argued his own case before the five justices, with a standby lawyer, Joseph Bernstein, beside him. "I do not oppose the death penalty in this case," he told them. The court affirmed on February 18, in an opinion by Justice Holland, and noted that the trial judge had made clear Pennell’s own request played no part in the sentences. He was executed by lethal injection near Smyrna on March 14, 1992. He never admitted any of the killings.
Joseph Paul Franklin represented himself, in whole or in part, in at least three of the trials that put him in prison for life or on death row. In Madison, Wisconsin, in February 1986, Judge William Byrne let him represent himself with a standby lawyer. Franklin told the jury his confession was invented and that he had learned the details from newspapers. He called no witnesses. The jury deliberated a little more than an hour and convicted him of two murders, and he received two consecutive life sentences.
The Missouri case, over the 1977 murder of a man in St. Louis County, put him on death row. A defense psychiatrist diagnosed paranoid schizophrenia in 1996 and judged him not competent to stand trial. A state psychiatrist diagnosed a personality disorder but no mental disease and judged him competent. The trial court agreed with the state’s expert. Franklin then asked to represent himself, citing disagreements with his lawyers. After a second hearing the court ruled that the waiver was knowing and voluntary, let him proceed on his own and ordered the lawyers to stay on as advisory counsel. He took part in jury selection, cross-examined witnesses and called one witness. A St. Louis County jury convicted him of capital murder, and, in a trial in which he asked the jurors for a death sentence, sentenced him to death in 1997. In Ohio in 1998 he acted as his own co-counsel; after a day of testimony a Hamilton County jury took about 45 minutes to convict him of two counts of aggravated murder.
About two months after the Missouri verdict Franklin said he had changed his mind and asked to file a late appeal. The Missouri Supreme Court refused. In federal court the matter went further than in most cases. The district court granted relief on two grounds, one of them that his waiver of counsel had not been knowing, voluntary and intelligent. On July 24, 2007, the Eighth Circuit reversed in Franklin v. Luebbers. It held that the state courts' finding of competence had not been rebutted, and that his voluntary waiver of his direct appeal was a procedural default barring review of every claim. It sent the case back with directions to dismiss the petition.
The same questions about his mind returned in the last days. The Missouri Supreme Court rejected a claim that he was incompetent to be executed on November 19, 2013. A federal judge granted a stay that evening so the claim could be examined, but an appeals court overturned it, and early on November 20 the U.S. Supreme Court let that ruling stand without comment. He was executed by lethal injection at the state prison in Bonne Terre that morning. The Associated Press counted eight murder convictions in total.
The route by which William Neal came to represent himself is unusual because a prosecutor helped to prepare it. Neal was wanted in Lakewood, Colorado, in July 1998 in connection with three deaths that came to light that week. He told deputies by telephone that he wanted to surrender but first wished to speak to a lawyer. When the number he supplied proved to be out of service, he asked for a public defender. None was contacted. A senior Jefferson County prosecutor, Pautler, took the telephone line and presented himself as a public defender named "Mark Palmer." He spoke to Neal for less than seven and a half minutes of a three-and-a-half-hour exchange and never said he was a prosecutor. Neal surrendered that evening.
When the actual public defender’s office sent a lawyer, Neal said he already had one, Mark Palmer. The office told him no one by that name worked there. Neal then dismissed the public defenders and went on with court-appointed advisory counsel. Whether the deception caused the break was disputed in the later proceedings. A 2004 law review article argued that it did, quoting Neal as saying he could not trust any lawyer after one had lied to him. Pautler was disciplined, and in a decision of May 13, 2002, the Colorado Supreme Court upheld the sanction.
In February 1999, representing himself, Neal pleaded guilty before Judge Thomas Woodford, who questioned him for nearly an hour. He pleaded to three counts of first-degree murder along with sexual assault, kidnapping and menacing counts, telling the judge he was guilty "without a doubt, your honor." His advisory counsel, Randy Canney, doubted that he was prepared and threatened to argue he was not competent to represent himself. Neal answered that a psychiatrist had seen no reason to think so.
The sentencing was heard by three judges, not a jury. Neal again represented himself, raised no objections and promised not to cross-examine the surviving woman or the families. He conceded that every aggravating factor the state alleged was present and offered three mitigating ones. His sister testified in support of a competency challenge, saying he moved between rational and incoherent speech within a single conversation, and Judge Woodford rejected it. On September 29, 1999, the panel sentenced him to death, rejecting every mitigating factor and writing that his plea "rings hollow in light of his past deceits and evil deeds." A 2004 law review article reported his appeal of the plea and sentence as pending.
Joseph Duncan pleaded guilty in Idaho state court in October 2006 to three first-degree murders and three kidnappings, with a public defender at his side. In federal court, on December 3, 2007, with counsel and no plea agreement, he pleaded guilty to all ten counts before U.S. District Judge Edward J. Lodge in Boise. Neither plea was a solo act. Self-representation entered the case only at the penalty phase.
Jury selection began on April 14, 2008. On the second day Duncan told the judge he wanted to represent himself. Judge Lodge questioned him and sent him to a court-appointed psychologist, who judged him competent. On May 2 his lawyers moved for a ruling that he was incompetent, or at least for a hearing. Three defense experts had concluded that delusions and impaired judgment left him unable to represent himself, and the defense pointed to brain imaging and to his own writings. The court ordered a six-week evaluation by the Bureau of Prisons. Duncan largely refused to take part, but the forensic psychologist there reported no psychosis and concluded he could represent himself. On July 24, 2008, Judge Lodge denied a competency hearing, preferring the court’s experts and pointing to Duncan’s rational conduct in court and at the plea hearing. Duncan was allowed to proceed alone, with his three lawyers on standby.
The penalty hearing opened August 13, 2008. The government presented evidence for ten days. Duncan called one witness, himself, offered nothing in his own defense and told the court, "I have no argument." After about three hours the jury recommended death on all three capital counts, and on August 27 Judge Lodge imposed three death sentences. In November his standby lawyers filed a notice of appeal. Duncan wrote that it was "done contrary to my wishes," and at a hearing on November 24 he said he understood his right to appeal and did not want to use it. Judge Lodge ruled the waiver competent and struck the notice.
The Ninth Circuit disagreed that the record was complete. On July 11, 2011, a panel in an opinion by Judge Graber held that standby counsel had standing to appeal, because a lawyer may challenge a competency ruling when lawyer and client actively dispute it. The opinion held that the defense experts, the brain imaging and Duncan’s writings raised a reasonable doubt, so federal law required a full competency hearing. The court expressed no view on which experts were more persuasive and sent the case back for a retrospective hearing. In December 2013 the district court again ruled Duncan competent, and in March 2016 the U.S. Supreme Court declined to hear his appeal on the question. His California case had run in parallel. In Riverside County, a jury in Indio ruled him competent to stand trial in August 2009, after a four-week hearing at which six psychologists and psychiatrists testified. He then acted as his own lawyer for about a year, and in October 2010 asked for a public defender. He pleaded guilty to murder, with other charges, in March 2011 and received life terms on April 5, 2011. He died on March 28, 2021, on federal death row at Terre Haute, Indiana.
John Allen Muhammad’s Virginia trial began on October 20, 2003, in Virginia Beach, and on its first day he dismissed his court-appointed lawyers and represented himself. He kept the role for two days, then asked his standby lawyers to take the case back. The judge, LeRoy Millette Jr., did not allow a hybrid arrangement in which standby counsel acted as co-counsel, and moved them farther from him, a change Muhammad had proposed and agreed to. The jury convicted him of capital murder and conspiracy, and he was sentenced to death in March 2004.
His state habeas petition argued that he had been allowed to represent himself without proper warnings or an inquiry into his competence. The Supreme Court of Virginia dismissed it in 2007, and it noted that his own refusal to cooperate with the state’s expert had kept expert mental health testimony out of sentencing. In August 2009 the Fourth Circuit affirmed the denial of federal relief. It assumed his lawyers should have objected to his self-representation but ruled that he suffered no prejudice, since he had represented himself for only two days with standby counsel closely involved.
The Maryland case was different. When jury selection began in Rockville on May 1, 2006, Muhammad represented himself throughout, with J. Wyndal Gordon and Jai Bonner as standby attorneys. He called the case a frame-up. His co-defendant, Lee Boyd Malvo, then 21, testified for the prosecution, and Muhammad cross-examined him himself, putting questions to him about his mental health, his insanity defense in Virginia and the claims he had made shortly after his arrest. On May 30, 2006, the jury returned six first-degree murder verdicts, and on June 1 the judge imposed six consecutive life terms. In November 2007 the Court of Special Appeals affirmed. It held that the trial judge’s questioning had shown Muhammad’s solid understanding of what self-representation involved, that his decision was "no spur-of-the-moment impulse," and that the case against him was so overwhelming that no error could have changed the verdicts. Muhammad was executed in Virginia on November 10, 2009, still denying any part in the crimes.
Joseph Naso, a photographer in his late seventies, faced four murder counts in Marin County for deaths between 1977 and 1994. Prosecutors told the court he had up to a million dollars in assets, enough to hire counsel. He chose to represent himself, a Marin judge allowed it, and a deputy public defender, Pedro Oliveros, was assigned as advisory counsel.
His closing argument took all of a Friday and half of the following Monday. He portrayed himself as a confused, cantankerous grandfather prosecuted for unusual tastes he had never acted on, and argued that his DNA showed at most that he had been with one of the women, not that he had killed her. The judge repeatedly told him to stop discussing evidence that was not in the record and warned that he could end the argument and have a public defender finish it. On August 20, 2013, the jury convicted him of all four murders with the special circumstance of multiple murder, and in November 2013 he was sentenced to death for three of the murders and life without parole for the fourth. He has always denied killing anyone.
The automatic appeal to the California Supreme Court, People v. Naso, S214917, was still at the briefing stage more than a decade after the trial. The court extended the time to file his opening brief in 2023 and again in February 2024, to April 22, 2024. In September 2025 ABC7 reported that he was arguing, among other claims, that the trial judge should not have let him represent himself because he was a naive defendant. "This trial should be reversed," he told the station. No ruling had been reported as of September 2025.
Rodney Alcala is the only defendant here whose earlier lawyers helped to defeat his own convictions. Orange County juries convicted him of a 12-year-old girl’s murder in 1980 and again in 1986, and both judgments fell. The California Supreme Court reversed the first in 1984 because the jury had heard about his earlier offenses. The federal courts set aside the second. In a 2003 opinion the Ninth Circuit held that his trial lawyers had failed to call an employee and present business records that supported his alibi, and that the exclusion of an expert on a key witness’s account had violated due process, adding up to "multiple constitutional errors that had a substantial and injurious effect on the jury’s determination of guilt."
By the third trial, in Santa Ana in January 2010, the case had grown to include four other murders in Los Angeles County, all joined with the first by a 2008 ruling of the California Supreme Court. Alcala, 66, represented himself. His opening statement lasted about an hour and did not mention the four Los Angeles County women; he concentrated on the girl’s death, telling jurors the police had nothing connecting him to her and that he had been elsewhere. He cross-examined her mother, showed a clip of a 1978 television appearance to argue that a pair of earrings was his, and took the stand to question himself, which allowed prosecutors to tell the jury about his earlier convictions. At the penalty phase he played part of a folk song for the jurors, and the girl’s brother left the courtroom. Prosecutor Matt Murphy called the Los Angeles County cases a "slam-dunk," and Alcala offered almost no challenge to the evidence in them.
On February 25, 2010, after six weeks of testimony and less than two days of deliberation, the jury convicted him of five first-degree murders and one count of kidnapping. It recommended death on March 9, and Judge Francisco Briseno imposed the sentence on March 30. In December 2012 he pleaded guilty in Manhattan to two murders from the 1970s, saying he wanted the New York case behind him so he could return to California and pursue his appeal; he had complained in letters that jailers there would not give him a laptop or his legal papers. He was sentenced to 25 years to life on January 7, 2013, and died of natural causes on July 24, 2021. No decision on the automatic appeal of the 2010 judgment has been reported.
Steven Dean Gordon went to trial in Santa Ana in November 2016 on four counts of special-circumstances murder, and from the opening statements he acted as his own lawyer. He had confessed to police in 2014, and his co-defendant, Franc Cano, was to be tried separately. The prosecutor was Larry Yellin. On December 15, 2016, the jury convicted Gordon of all four murders, with the special circumstances of kidnapping and multiple murder.
At the penalty phase, still without a lawyer, Gordon asked the court to remove a juror whom he feared might be the only holdout against death. "I think if she stayed and with the other 11 voted death, the case is going to be overturned, and I don’t want that," he said. Minutes later the jury announced a decision and recommended death. Gordon told the court that people who kill in cold blood deserve to die and that he believed it. He admitted taking part in most of the abductions and killings but maintained that Cano had been the one who hunted down and killed the women. Reporting in 2022 summed up the posture of the trial: representing himself, he had in effect conceded that he deserved execution.
He was sentenced to death on February 3, 2017. The District Attorney described the automatic appeal as ongoing in December 2022. Cano, who had pleaded not guilty in 2014, pleaded guilty as charged on December 15, 2022, and was sentenced at once to life without parole. "Today, I, Franc Cano, take full responsibility for my own previous actions," he told the court.
Read together, the eleven cases describe not one doctrine but at least four. Pennell, Cole and Gordon used self-representation to reach a sentence they had decided they wanted, and the courts that heard them responded in the same way: more inquiry, more standby counsel, more mandatory review. The Delaware and Nevada supreme courts insisted on reviewing the record even after the defendant had asked them not to. Clark and Alcala tried to run a defense and met a different set of limits. A California judge took the right away from Clark for abusive remarks and reappointed lawyers, a decision four courts have upheld over forty years. An Orange County judge let Alcala run the whole case and watched him try, with little success, to talk his way past the Los Angeles County evidence.
Bundy, Franklin, Duncan and Neal raised the issue that matters most at the appellate level: whether the defendant was competent to choose. Each answer came down to which expert a judge believed. Judge Sharp preferred two psychiatrists to one and ruled Bundy competent. The Missouri trial court preferred the state’s psychiatrist to the defense’s and let Franklin go on alone. Judge Lodge preferred the court’s experts to three defense experts, and the Ninth Circuit ordered a hearing anyway. And Muhammad and Naso show the other end of the spectrum: courts affirming a waiver as knowing and voluntary with little dispute, only to have the question come back years later as the centerpiece of an appeal.
Nothing in these records shows that a lawyer would have changed a verdict. In several of them the evidence was, as one appellate court said of Muhammad’s, overwhelming. What the cases do show is that the cost of self-representation to the legal system is rarely in the trial itself. It arrives afterward, in the habeas petitions, the retrospective competency hearings and the opinions that spend more pages on who was speaking than on what was said.
• 1975: The Supreme Court decides Faretta v. California, recognizing a defendant’s right to represent himself.
• 1977: Ted Bundy chooses to act as his own lawyer in Colorado; the case is never tried.
• June 25, 1979: Bundy’s televised Florida trial opens in Miami; he acts as one of his own lawyers.
• August 13, 1982: Douglas Clark asks to represent himself; August 20, request denied as untimely.
• October 12 to 13, 1982: Clark allowed to represent himself, with standby counsel.
• December 6, 1982: Clark’s self-representation revoked for good.
• March 16, 1983: Clark sentenced to death.
• October 12, 1984: Carroll Cole sentenced to death in Nevada after representing himself at the penalty hearing.
• October 22, 1985: Nevada Supreme Court holds Cole validly waived his appeal.
• December 6, 1985: Cole executed.
• February 10, 1986: Franklin’s Wisconsin trial opens; he represents himself with a standby lawyer.
• 1987: Judge Sharp holds Bundy competent at his 1980 trial.
• January 24, 1989: Bundy executed.
• October 11, 1991: Steven Pennell allowed to represent himself.
• October 30, 1991: Pennell’s no contest pleas accepted.
• February 11, 1992: Pennell argues his own case before the Delaware Supreme Court.
• March 14, 1992: Pennell executed.
• July 30, 1992: California Supreme Court affirms Clark’s murder convictions and death judgment.
• 1997: Franklin sentenced to death in Missouri after representing himself.
• 1998: Franklin convicted in Ohio, acting as his own co-counsel.
• February 1999: William Neal pleads guilty while representing himself.
• September 29, 1999: Neal sentenced to death by a three-judge panel.
• May 13, 2002: Colorado Supreme Court upholds discipline of the prosecutor who posed as Neal’s public defender.
• October 20, 2003: Muhammad’s Virginia trial opens; he represents himself for two days.
• May 2006: Muhammad represents himself throughout his Maryland trial.
• July 24, 2007: Eighth Circuit reverses the grant of habeas relief to Franklin.
• August 27, 2008: Joseph Duncan, representing himself at the penalty phase, sentenced to death.
• November 10, 2009: Muhammad executed.
• February 25, 2010: Rodney Alcala, representing himself, convicted in Orange County.
• July 11, 2011: Ninth Circuit orders a competency hearing in Duncan’s case.
• August 20, 2013: Joseph Naso, representing himself, convicted in Marin County.
• November 2013: Naso sentenced to death.
• November 20, 2013: Franklin executed.
• December 2016: Steven Gordon, representing himself, convicted and then given a death recommendation.
• February 3, 2017: Gordon sentenced to death.
• March 28, 2021: Duncan dies on federal death row.
• July 24, 2021: Alcala dies.
• October 10, 2023: Ninth Circuit affirms denial of Clark’s habeas petition; Clark dies the next day.
• September 2025: Naso argues in his appeal that he should not have been allowed to represent himself.