United States v. Quiles-Olivo, No. 10-1864 (1st Cir. 2012)
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Quiles visited the federal courthouse in Puerto Rico to verify the status of civil cases he had filed pro se. Disgruntled that his cases had been dismissed and by his inability to obtain counsel, he dressed in a shirt with the message "Desobediencia Civil", hidden under another shirt. After passing security and filing a motion expressing his discontent, he reviewed the status of his cases on the court's electronic system, turned his shirt, revealing the message, and destroyed the computer monitor and scanner. His acts of defiance completed, Quiles lay on the ground with his hands behind his back. The Clerk's Office replaced the scanner for $2,322.85 and installed a spare monitor. The government charged Quiles with depredation of U.S. property resulting in damages exceeding $1,000.00, 18 U.S.C. 1361. When Quiles failed to comply with conditions of bail, the court issued a warrant, ordering him detained until trial. The district court denied appointed counsel's motion for a continuance on the grounds that the pro se motion for a change of venue had not been found. The court denied oral requests for change of venue and recusal of the judge. Quiles was convicted and sentenced to time served and restitution. The First Circuit affirmed
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