Holding: The Ninth Circuit erred in granting habeas relief to respondent Otis Lee Rodgers, who argued that the state courts violated his Sixth Amendment right to effective assistance of counsel when it failed to appoint an attorney to help him file a motion for a new trial, even when he had waived his right to an attorney on three previous occasions. Even assuming that, after a defendant validly waives his right to trial counsel, a post-trial, preappeal motion for a new trial is a critical stage of the prosecution, the Ninth Circuit’s holding that respondent’s Sixth Amendment right to counsel was violated was not supported by clearly established federal law; the courts of appeals may not rely on circuit precedent to refine or sharpen a general principle of Supreme Court jurisprudence into a specific legal rule that the Court has not announced.
Judgment: Granted, reversed in a per curiam opinion on April 1, 2013.
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