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United States v. Kaczynski
United States Court of Appeals for the Ninth Circuit
239 F.3d 1108 (2001)
Theodore Kaczynski (defendant), known as the Unabomber, was indicted for mailing or placing 16 bombs that killed three people and injured numerous others. Kaczynski’s attorneys intended to assert an impaired-mental-state defense, to which Kaczynski vehemently objected. Kaczynski preferred to argue that the bombings were self-defense against technological society. After 16 days of voir dire, during which Kaczynski conferred with his counsel while they selected jurors who appeared receptive to a mental-impairment defense, Kaczynski again objected to the pursuit of that defense. Kaczynski later agreed to the introduction of evidence of his mental state during the penalty phase of the trial but not during the guilt stage. Then, however, Kaczynski sought to replace his counsel with an attorney he had identified who would defend the case the way Kaczynski wanted. When the district court denied that motion, Kaczynski asked to represent himself. The court ordered a competency evaluation, which resulted in a finding that Kaczynski was competent to stand trial. The court then denied the self-representation motion on the grounds that it was made in bad faith and constituted an attempt to delay the trial. The court noted that the government intended to offer more than 1,300 exhibits at trial, along with extensive technical evidence, which would have prevented Kaczynski from immediately assuming his own defense of the case. The court also determined that Kaczynski was motivated not so much to avoid evidence of his mental state but rather to project a desired image of himself and improve his prospects for a plea. Kaczynski pleaded guilty in exchange for the government (plaintiff) agreeing not to seek the death penalty and was sentenced to life without parole. Kaczynski then appealed, arguing that his guilty plea was not voluntary because he was wrongly denied the right to represent himself.
Rule of Law
Holding and Reasoning (Rymer, J.)
Dissent (Reinhardt, J.)
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