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United States v. Beckton
United States Court of Appeals for the Fourth Circuit
740 F.3d 303 (2014)
Reggie Beckton (defendant) was charged with bank robbery. After being unhappy with three different public defenders, Beckton chose to represent himself, despite the trial judge’s advice to the contrary. At trial, Beckton decided to testify in his own defense. The court permitted this testimony but warned that Beckton was not permitted to testify in narrative form. The court again offered counsel to Beckton, but he again refused. At the court’s direction, Beckton agreed that he would ask himself questions and then answer the questions. Despite this warning, Beckton testified in narrative form. The judge temporarily excused the jury and again told Beckton that testimony must be in question-and-answer format. The judge also again offered counsel. Beckton again refused and agreed to ask himself questions. Back in front of the jury, Beckton again testified in narrative form, at which point the judge asked the jury to leave again. The judge told Beckton that he could either continue to represent himself but not testify or accept counsel. Beckton chose the former, was convicted, and appealed.
Rule of Law
Holding and Reasoning (Motz, J.)
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