U.S. v. Stapleton

In prosecution on sex-trafficking charges to which defendant had pleaded guilty and received life sentence, Dist. Ct. did not commit plain error in denying defendant’s motion to withdraw his guilty pleas, even though defendant argued that his guilty pleas were invalid, because: (1) he was without counsel at time he entered into guilty pleas at start of trial; (2) he was denied his right to counsel because his waiver of counsel was made under circumstances where he did not know his appellate rights at time of his waiver; and (3) his guilty pleas were unknowing and involuntary. Ct. of Appeals, in rejecting defendant’s claims, noted that: (1) defendant was appointed several counsel, who were either removed at defendant’s request or who had filed motions to withdraw; and (2) Dist. Ct. subjected defendant to two thorough Faretta hearings, where defendant confirmed that he understood charges against him and severe penalties he faced if convicted on said charges, and that he understood that Dist Ct. could not advise him on how to try his case; and (3) Dist. Ct. reminded defendant that legal counsel would represent him far better than defendant could represent himself. Record also showed that Dist. Ct. fully complied with requirements set forth in Rule 11(b). Dist. Ct. also did not err in denying defendant’s pro se request for court-funded expert to investigate certain settings on defendant’s cellphone, where: (1) defendant failed to produce any credible evidence that police had tampered with settings in his cellphone to obtain incriminating evidence; and (2) defendant’s request failed to identify expert or expert’s likely testimony and did not estimate expert’s cost.