United States v. Laphonse Young

DUBINA, Circuit Judge:

In this case, we consider an issue of first impression in this circuit: whether a defendant’s right to proceed pro se is unqualified if the defendant asserts his request after the jury is empaneled but before the jury is sworn. Following the dictate of Chapman v. United States, 553 F.2d 886 (5th Cir.1977), 1 and several other circuits’ interpretive holdings, we hold that a defendant’s right of self-representation is unqualified if the defendant asserts that right before the jury is empaneled, absent any indication that the defendant is attempting to delay the…