United States v. Taylor, No. 10-2758 (8th Cir. 2011)
Annotate this CaseDefendant was convicted of bank robbery and appealed his conviction, arguing that he was entitled to a new trial because the district court abused its discretion when it denied his repeated pretrial requests for new appointed counsel, which rendered involuntary his ultimate decision to waive his Sixth Amendment right to counsel and defend himself at trial. The court held that defendant failed to show that his attorney was unprepared, unable or unwilling to continue representing defendant, or had failed to take actions on behalf of defendant that would cause "justifiable dissatisfaction" with the quality of the attorney's advocacy. The court also held that there was no breakdown of communication requiring appointment of new counsel where defendant was unwilling to communicate with appointed counsel. Therefore, the district court did not abuse its discretion in declining to grant defendant's request for new counsel. The court further held that the district court properly cautioned defendant as to the dangers of self-representation and a "persistent, unreasonable demand for dismissal of counsel and appointment of new counsel... [wa]s the functional equivalent of a knowing and voluntary waiver of counsel." Therefore, the court denied defendant's pro se motion claiming ineffective assistance of appellate counsel and affirmed the judgment of the district court.
Court Description: Criminal case - criminal law. District court made a careful and thorough inquiry into defendant's repeated claims of dissatisfaction with his appointed counsel and did not abuse its discretion by denying the motion; by the time of trial, it was clear that the attorney-client relationship had broken down, and the court did not err in relieving counsel and refusing to appoint substitute counsel; a persistent, unreasonable demand for dismissal of counsel and appointment of counsel is the functional equivalent of a voluntary waiver of counsel, and the court did not err in proceeding to trial with defendant representing himself.
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