United States v. Conklin, No. 15-2140 (8th Cir. 2016)
Annotate this CaseDefendant appealed his conviction for distributing methamphetamine and heroin, arguing that the district court violated his Sixth Amendment right to counsel because he did not unequivocally state his intent to proceed pro se. In this case, defendant refused to state whether he wished to be represented at trial by counsel, either appointed or retained, or to represent himself. The court concluded that, given the district court’s thorough and repeated explanation of the dangers of self-representation, the court's decision in United States v. Sanchez-Garcia applies. In Sanchez-Garcia, the court held that by repeatedly rejecting all options except self-representation, after having been warned of the consequences, the defendant necessarily chose self-representation. Accordingly, the court affirmed the judgment.
Court Description: Loken, Author, with Wollman and Benton, Circuit Judges] Criminal case - Criminal law. Defendant waived his Sixth Amendment right to counsel, and the district court did not err in allowing him to proceed to trial pro se; an accused can waive his right to counsel by his conduct; where a defendant refuses to answer the court's questions as to whether he wants to be represented at trial or proceed pro se, refuses appointed counsel and refuses to retain counsel, and where the court properly and repeatedly explains the right to counsel and the dangers of proceeding without one, the court is authorized to find a knowing, voluntary and intelligent waiver of the right to counsel.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.