United States v. Woodard

BOWNES, Senior Circuit Judge.

Defendant-appellant Deborah Woodard appeals from a criminal judgment entered against her on the ground that she was deprived of counsel in violation of the Sixth Amendment to the United States Constitution. On the eve of trial, Woodard requested substitution of counsel. The court refused and told Woodard that she could either continue with her present counsel or represent herself; if she represented herself, her counsel would remain available to help her if she wished. Later, the court told Woodard she could bring in new counsel if she could do so in time for…