United States Eighth Circuit

Defendant's conviction for distribution of a controlled substance is affirmed where: 1) the record did not suggest that defendant's counsel was unprepared or inadequate as counsel, and thus defendant was not effectively compelled to represent himself; 2) despite defendant's admission that his self-representation request was both untimely and for an improper purpose, neither concession served as a basis for reversing the district court's decision to grant his request; 3) there was no abuse of discretion in the district court not ordering a competency evaluation or holding a competency hearing; and 4) there was sufficient evidence to sustain defendant's convictions.

Appellate Information

• Decided 03/05/2010
• Published 03/05/2010

Judges

Court

• United States Eighth Circuit

Counsel