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United States Fourth Circuit

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US v. Bernard, 11-4054

District court's decision allowing defendant to represent himself at trial despite his questionable mental capacity, is affirmed, where: 1) it is permissible for a trial court, having found a mentally ill defendant competent to stand trial, to determine him to be competent to waive his Sixth Amendment right to counsel; 2) in light of the circumstances as a whole, the district court did not err in finding defendant competent to waive his right to counsel; 3) the district court did not abuse its discretion in not reconsidering its decision; and 4) defendant's claim of ineffective assistance of counsel fails.

Appellate Information

  • Decided 02/28/2013
  • Published 02/28/2013




  • United States Fourth Circuit


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