How have courts dealt with cases where a defendant was unknowingly represented as a lawyer by a lawyer who had never been admitted to membership of any bar?

MultiRegion, United States of America

The following excerpt is from U.S. v. Hoffman, 733 F.2d 596 (9th Cir. 1984):

In the related situation where a defendant was unknowingly represented by a person posing as a lawyer, but who had never been admitted to membership in any bar, several courts have applied a per se rule and found that the right to counsel was violated. E.g., Solina v. United States, 709 F.2d at 168 (graduate of accredited law school who had failed New York

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