United States v. Rivera, No. 17-59 (2d Cir. 2022)
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Defendant appealed his conviction following a jury trial in district court in which he was found guilty of racketeering, murder in aid of racketeering, various narcotics offenses, interstate prostitution, and sex trafficking of minors. On appeal, Defendant argued that the district court erred by permitting him to represent himself without a psychiatric evaluation.
The Second Circuit affirmed the judgment holding that while the district court has the discretion to conduct an inquiry into a defendant’s mental competence before granting a motion to proceed pro se, the court is not required to order psychiatric testing and did not err in granting Defendant’s motion. The court explained that where a defendant has been found competent to stand trial Edwards does not require a court to conduct a further competency hearing or order psychiatric evaluations before permitting a defendant to proceed pro se. (Indiana v. Edwards, 554 U.S. 164 (2008).) Further, on the current facts, the court could not say that the district court abused its discretion in failing to sua sponte order a psychiatric evaluation prior to determining that Defendant “knowingly and intelligently” waived his right to counsel.
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