USA v. Thomas Noble, No. 20-1599 (3d Cir. 2022)
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Defendant was indicted for various child pornography offenses in February 2018. Defendant expressed his intention to represent himself and the district court permitted him to do so, but appointed the Federal Public Defender's Office as standby counsel. However, subsequently, Defendant announced to the court he was invoking his Fifth Amendment right to remain silent and largely refused to participate in the proceedings. After holding a hearing, the district court held that Defendant waived and forfeited his right to represent himself and appointed the Federal Public Defender's Office as his attorney. Ultimately, Defendant was convicted and sentenced to 180 months of imprisonment.
On appeal, Defendant challenged the district court's determination that he waived and forfeited his right to represent himself. The court affirmed Defendant's conviction. The court explained "the right to represent oneself is not absolute, however; judges 'may terminate self-representation by a defendant who deliberately engages in serious and obstructionist misconduct.'" Here, Defendant stopped communicating with the court, failed to open his legal mail and repeatedly violated court orders. Thus, the Third Circuit held that the district court did not err in concluding that "it would be impossible to conduct a fair trial with a pro se defendant who refused to cooperate or engage at all with the court."
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