U.S. v. Boultinghouse

In prosecution on petition to revoke defendant’s supervised release, Dist. Ct. did not err in granting defendant’s request to represent himself during revocation hearing. Revocation proceeding is much less formal than trial on criminal charges, and record showed that defendant was capable of making knowing waiver of his right to counsel and did so intelligently, where record showed that defendant appreciated what was at stake, understood nature of revocation proceeding, knew identify of factual disputes, was aware that lawyer might be able to do better job than he could and was directly advised by Dist. Ct. not to waive representation. Fact that Dist. Ct. did not expressly discuss defendant’s education, level of sophistication or experience with legal system did not require different result. Also, fact that defendant did not do particularly effective job in advancing his claim was irrelevant where: (1) it was not obvious that defendant’s claim would have been successful had he been represented; and (2) record demonstrated that defendant’s choice to represent himself was “informed,” even though it might not have been “right” or “smart.”