United States v. Prucha, No. 16-3014 (8th Cir. 2017)Annotate this Case
Defendant moved to proceed pro se for the fourth time on the third day of trial. The Eighth Circuit affirmed the district court's denial of his motion, holding that defendant's motion was untimely. In this case, defendant made the motion midway through the third day of trial, he was not prepared to represent himself, and just because the district court advised defendant that he could make his motion to proceed pro se at any time did not make his motion timely.