United States v. Doyle Smith

LOKEN, Circuit Judge.

Stripped to its essence, this appeal raises the question whether denial of a criminal defendant’s timely request to represent himself at trial because he had not complied with prescribed pretrial procedures and might be planning to make arguments the district court would consider “improper” violated his Sixth Amendment right of self-representation. A jury found Doyle D. Smith guilty of corruptly obstructing administration of the internal revenue laws, willfully subscribing to false federal tax returns, and mailing a false negotiable instrument to a state agency with…