United States v. Prucha, No. 16-3014 (8th Cir. 2017)
Annotate this CaseDefendant moved to proceed pro se for the fourth time on the third day of trial. The Eighth Circuit affirmed the district court's denial of his motion, holding that defendant's motion was untimely. In this case, defendant made the motion midway through the third day of trial, he was not prepared to represent himself, and just because the district court advised defendant that he could make his motion to proceed pro se at any time did not make his motion timely.
Court Description: Fenner, Author, with Smith, Chief Judge, and Shepherd, Circuit Judge] Criminal case - Criminal law. A motion to proceed pro se made on the third day of trial was untimely, and the district court did not err in denying the motion.
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