United States v. Simpson, No. 09-30075 (5th Cir. 2011)
Annotate this CaseDefendant was indicted for various federal crimes, including, inter alia, conspiracy to traffic in narcotics, membership in a criminal enterprise, murder, and attempted murder. At issue was whether defendant was competent to stand trial; whether defendant's Sixth Amendment right to effective representation was violated; and whether defendant was entitled to a new round of jury selection after his co-defendant pleaded guilty. The court held that the district court's competency finding was neither arbitrary or unwarranted where, although defendant had some symptoms of paranoia, he was competent because he was able to consult with his attorneys with a reasonable degree of rational understanding and was able to understand the proceeding. The court also held that defendant was not entitled to the appointment of substitute counsel where he intentionally refused to cooperate with his able and diligent court-appointed lawyers, was given ample opportunity to communicate with them, and simply refused to do so. The court further held that the district court adequately explained what the counsel liaison's role was and that the district court did not interfere with the attorney-client relationship. The court also held that when one or more joint defendants faced the death penalty at the time the jury was selected, death-qualification was constitutionally permissible and the court further held that if all of the capital defendants plead guilty following voir dire, the trial court need not allow a new jury to be selected. In this instance, the jury had already been selected at the time the co-defendant entered his guilty plea and defendant did not allege that the jury instructions were deficient or rebutted the presumption that the jury properly applied its instruction. Accordingly, the judgment of the district court was affirmed.
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