William Ayers v. Johnathan Hall

KAREN NELSON MOORE, Circuit Judge.

William Ayers was an experienced criminal-defense attorney in Kentucky who found himself on the wrong end of counsel's table when he was indicted in 2008 on five counts of failing to file state tax returns. While Ayers undeniably represented himself throughout the twenty-one months between his indictment and his trial, it is undisputed that he never formally elected to do so: he never waived his right to counsel on the record, "file[d] a notice of appearance of any kind, appear[ed] with a co-counsel for any purpose, or file[d] a motion to be allowed to…