Tyler v. State: Backman case. Faretta/Nelson issue. Backman is affirmed because the court found that Tyler was doing nothing more than trying to delay his trial. You know the court was going to affirm when the court stated: "[t]o say Tyler was caught red-handed is an understatement."

Martoral v. State: Gardiner case. Defendant is charged with violating his probation. As to the allegation that he changed his residence without prior approval, the court held that moving from one room at a Howard Johnson motel to another room without telling the probation officer is not a willful and substantial violation. Next, Martoral was alleged to have possessed marijuana. This is a typical case of two people sitting in a car and the bag of weed is was in plain view on the dashboard. The legion of constructive possession cases would mandate a JOA at a trial. This case holds that there was no violation even with the much lesser standard of proof necessary to prove a VOP.

Holcomb v. State: Gardiner case. The issue in this case is whether it is proper to give the recently stolen property presumption when the defendant is in constructive as opposed to actual possession of the stolen property. The court held that the instruction was proper because the Defendant was the sole occupant of the car in which the stolen goods were found.