United States v. Miller, No. 12-2821 (8th Cir. 2013)
Annotate this CaseDefendant appealed his conviction of four counts of making false claims against the United States. The court concluded that the district court did not err by not conducting a third Faretta inquiry where defendant had the benefit of two prior hearings and the district court was satisfied that his election to proceed pro se was knowing and voluntary under all the circumstances, and the court rejected defendant's claims of error. The court also concluded that there was sufficient evidence to convict defendant. Accordingly, the court affirmed the judgment of the district court.
Court Description: Criminal case - Criminal law. The district court did not err by not conducting a third Faretta inquiry, as the district court had rigorously complied with Faretta's requirements at the first two inquiries and defendant's statements during closing argument did not show changed circumstances necessitating another hearing; evidence was sufficient to support defendant's convictions for making false claims against the United States.
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