Is a waiver of a plaintiff's right to counsel after the preliminary hearing invalid?

MultiRegion, United States of America

The following excerpt is from Williams v. Clark, No. 2:09-cv-2968 JAM CKD P (E.D. Cal. 2015):

Petitioner asserts that the trial court only sought a waiver of his right to an attorney before the preliminary hearing, but did not re-advise petitioner of his right to counsel after the hearing, in violation of California law. (Ptn. at 147-148.) As "federal habeas corpus relief does not lie for errors of state law," Estelle v. McGuire, 502 U.S. 62, 67 (1991), this claim is not cognizable under 2254 and should be denied.

4. Jury Instruction Error

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