United States v. Bunch, No. 11-2113 (8th Cir. 2012)
Annotate this CaseTorrance Bunch and Fernando Sanchez-Garcia were each convicted by a jury of conspiracy to possess with intent to distribute 500 grams or more of methamphetamine. The jury also found Bunch guilty of three counts of distribution of five grams or more of methamphetamine. On appeal, Bunch alleged that he was denied his Sixth Amendment right to counsel, and Sanchez-Garcia contended that the district court erred in denying his motion for a mistrial and committed other trial-related errors. The Eighth Circuit Court of Appeals affirmed, holding (1) by repeatedly rejecting all options except self-representation, after having been warned of the consequences, Bunch necessarily chose self-representation, and thus, the district court's ruling did not violate Bunch's rights under the Sixth Amendment; (2) the prosecutor's comments during closing argument were not improper, and thus Sanchez-Garcia was not entitled to a mistrial; (3) the district court did not commit plain error by proceeding with a joint trial; and (4) the district court did not abuse its discretion by admitting a recording of a telephone call into evidence.
Court Description: Criminal case - Criminal law. Under the circumstances, and in light of the advice that the district court gave defendant Bunch before the trial commenced, the district court did not err in finding Bunch knowingly and intelligently waived his right to counsel; district court did not err in denying a mistrial after two witnesses made comments regarding defendant Sanchez-Garcia's immigration status as the first comment was unsolicited and the second comment was promptly addressed by the district court's action in striking the testimony; prosecutor's comments during closing were not an improper appeal to the jury to act as the conscience of the community; joint trial did not prejudice Sanchez- Garcia; under the circumstances, the court did not abuse its discretion by admitting a tape of a jailhouse phone call which was not disclosed to Sanchez-Garcia until three days before trial; claim of ineffective assistance of counsel would not be addressed.
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