United States v. Owen, No. 16-2521 (8th Cir. 2017)
Annotate this CaseDefendant challenged the revocation of his supervised release and 24 month sentence, arguing that his waiver of counsel and decision to proceed pro se were invalid. The court concluded that the totality of the circumstances demonstrated that defendant made a voluntary, knowing, and intelligent choice to represent himself at the revocation hearing. In this case, the magistrate judge had previously "strongly urged" defendant not to proceed pro se, defendant was well aware of the dangers of representing himself, defendant's age and extensive experience with the criminal justice system indicated that he was adequately equipped to make the decision to represent himself, and defendant had met with appointed counsel before the revocation hearing, although defendant never utilized him. Accordingly, the court affirmed the judgment.
Court Description: Riley, Author, with Smith and Benton, Circuit Judges] Criminal case - Criminal law. Considering the totality of the circumstances, defendant made a voluntary, knowing and intelligent choice to represent himself at his revocation hearing, and his claim that his waiver of counsel and decision to proceed pro se were invalid is rejected.
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