Federal 7th Circuit Court
Criminal Court
Waiver of Counsel
Defendant, who elected to represent herself during trial court proceedings, was charged with and found guilty of one count of mail fraud, five counts of theft from an employee benefit plan, 22 counts of filing false tax returns, and one count of failing to report income. On appeal, defendant argued that the district court erred when it allowed her to represent herself and requested a new trial. The Seventh Circuit affirmed, finding that her waiver of counsel was knowing and voluntary. (BRENNAN and KIRSCH, concurring)