United States v. Stanley, No. 16-4241 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit affirmed defendant's conviction of evasion of payment of taxes and corruptly endeavoring to impede enforcement of Internal Revenue laws. The court held that the district court adequately warned defendant of the dangers of self-representation and did not err in finding that he understood them and knowingly waived his right to counsel. The court also held that the district court did nor err giving Eighth Circuit Pattern Jury Instruction No. 2.23, which instructs the jury that where a defendant represents himself, it may only consider his testimony as evidence.
Court Description: Benton, Author, with Loken and Erickson, Circuit Judges] Criminal case - Criminal law. The district court and magistrate judge repeatedly advised defendant of the dangers of proceeding pro and offered solutions to address both his and the court's concerns, and the district court did not violate defendant's right to counsel by allowing him to proceed pro se; the district court did nor err giving Eighth Circuit Pattern Jury Instruction No. 2.23 which instructs the jury that where a defendant represents himself it may only consider his testimony as evidence.
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