“forfeited his right to court-appointed counsel by making threatening statements” to Phillipe. In reaching its conclusion, the court relied on Phillipe’s affidavit and the fact that Krause did not deny the content of the affidavit. Krause claims that his statements to Phillipe during their December 3, 2009, meeting do not constitute “extremely serious misconduct” warranting forfeiture based on the ease law of Minnesota or other jurisdictions. The only reported Minnesota case to hold that a defendant forfeited his right to counsel due to “extremely serious misconduct” is State v. Lehman, 749 N.W.2d 76, 79 (Minn.App.2008), which involved a defendant who physically attacked his court-appointed lawyer. In that case, the court of appeals stated 1705298, at *5 (S.D.N.Y. July 20, 2005) (<HOLDING>). Forfeiture of counsel has also been found in
holding that state courts determination that the petitioner was competent to waive his right to pursue further postconviction review of his claims was a factual one and therefore presumed correct under the federal habeas corpus statute holding that appellant forfeited his complaint regarding his sentence because he did not object at trial holding that petitioner had forfeited his right to object to psychiatric testimony by failing to raise the claim on initial appeal holding that defendant forfeited his right to counsel by verbally abusing and threatening to harm his attorney threatening to sue his attorney on four different occasions and attempting to persuade his attorney to engage in unethical conduct holding that a habeas petitioner was not entitled to relief from a state courts determination that he had forfeited his right to counsel by physically assaulting his attorney and threatening to put a contract on his attorneys life