United States v. Ronald J. Goldberg

OPINION OF THE COURT

COWEN, Circuit Judge.

We once again confront the tension caused when a criminal defendant appears to be manipulating his right to counsel in order to delay his trial. After relieving Ronald Goldberg’s court-appointed attorney, the district court refused his request for a continuance in order to retain private counsel. This forced Goldberg to stand trial without the assistance of counsel. The district court concluded that by his manipulative conduct, Goldberg had “waived” or, more properly, “forfeited” his Sixth Amendment right to counsel.

The question before us is whether…