R. v. Williams (C.L.) 2012 BCCA 314
Criminal Law - Procedure - Pleas - Whether voluntary
Williams was charged with robbery, dangerous driving and assault; impaired driving and obstruction of a police officer; and assault causing bodily harm and breach of a recognizance. Following his arrest on the last two charges, Williams was detained in custody. Acting on his own behalf, he pleaded guilty to impaired driving, assault, dangerous driving, and assault causing bodily harm. As a result of the guilty pleas, the Crown did not proceed with the other three charges. The convictions resulted in his incarceration for one further day. Williams appealed, seeking to have the pleas set aside on the basis that his convictions amounted to a miscarriage of justice. He alleged that he was compelled to plead guilty due to his frustration in his attempts to defend himself. Williams applied for an order appointing counsel to act for him on the appeal.
The British Columbia Court of Appeal, per Hinkson, J.A., in a decision reported at 301 B.C.A.C. 286; 510 W.A.C. 286, allowed the application for the appointment of counsel.
The British Columbia Court of Appeal dismissed the appeal. Williams failed to establish that his pleas were not validly entered.