United States v. Flowers

We have consolidated these two cases for the limited purpose of discussing a recurring issue that involves the gray area of where the district court’s authority ends and where our authority begins in the area of supervising trial attorneys who do not want to handle their client’s appeal. In both cases, the district court granted motions to withdraw filed after judgment was entered. We vacate both orders.

In 86-1514, an appeal of a criminal conviction, defendant Flowers was represented at trial by Steven R. Decker, his retained attorney. On the same day that Decker filed his client’s notice of…