United States v. Sandles

FLAUM, Circuit Judge.

After a four-day trial, a jury convicted John E. Sandies (“Sandies”) of five counts of bank robbery in violation of 18 U.S.C. § 2113(a). The district court sentenced San-dies to several concurrent terms of 180 months imprisonment and three years supervised release. On appeal, Sandies raises two issues: (1) whether he knowingly and intelligently waived his Sixth Amendment right to counsel; and (2) whether the district court abused its discretion in denying Sandies’ motion for substitute counsel. We vacate the conviction on the former ground, and remand for a new trial.…