United States v. Barksdale, No. 22-2284 (3d Cir. 2024)
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This case involves a criminal defendant, William Barksdale, who was denied the right to testify in his own defense during a supervised release revocation hearing. Barksdale had previously pled guilty to conspiring to commit wire fraud, was sentenced to twenty months in prison and five years' supervised release. Near the end of his supervised release, his probation officer reported ten potential violations of his release terms to the District Court. During the revocation hearing, Barksdale repeatedly expressed his desire to testify, but the judge denied his request, stating that Barksdale had chosen not to testify. The judge then found Barksdale guilty of nine release violations and sentenced him to thirty months in prison.
Barksdale appealed to the United States Court of Appeals for the Third Circuit, arguing that the District Court denied him his right to testify in his own defense. The Circuit Court reviewed the District Court's findings of fact for clear error, its legal rulings de novo, and its ultimate decision to revoke supervised release for abuse of discretion.
The Circuit Court found that on the record before them, the District Court judge had erred in denying Barksdale his right to testify. The Court ruled that nowhere on the record did Barksdale himself waive that right, and thus he was denied his constitutional right to testify. The government was then required to prove that this error was harmless beyond a reasonable doubt, which they failed to do. The Court noted that even if Barksdale's testimony could have reduced his sentence only slightly, that is enough to make the error harmful.
Finally, despite Barksdale's request for a new judge on remand, the Circuit Court found no evidence of bias or appearance of bias from the District Court judge. Therefore, the case was remanded to the same judge for a new revocation hearing.
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