United States v. Reed; United States v. Davis, No. 11-1462 (8th Cir. 2012)
Annotate this CaseGregory Allen Davis and Michael Howard Reed were convicted of conspiring to file and filing false liens against Judge Hovland and Jordheim in violation of 18 U.S.C. 1521. Reed was also convicted of corruptly obstructing justice in violation of 18 U.S.C. 1503(a). The court held that the evidence was sufficient to convict Davis of violating section 1521, whether or not it effectively impaired the government official's property rights and interests; having given the appropriate warnings and determined that the waiver of counsel was knowing and voluntary, the district court properly allowed Davis and Reed to exercise their constitutional right to self-representation; and the district court did not abuse its discretion in finding Reed competent to waive his right to counsel.
Court Description: Criminal Case - conviction. Evidence was sufficient the support conviction for violating 18 U.S.C. sec. 1521 based on filing of a false or fictitious lien, whether or not it effectively impaired the government official's property rights and interests. Record shows defendants made knowing and voluntary waiver of right to counsel and district court properly allowed defendants to exercise their constitutional right to self- representation. The district court did not abused its discretion in failing to determine if defendant was legally competent to waive his right.
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