U.S. v. Perry

Defendant was found guilty of sex-trafficking charges and argued on appeal that the district court erred when it denied his midtrial motion for a sixth court-appointed lawyer after he had elected to represent himself. Defendant argued that the trial court judge was required to consider his motives for changing his mind and to assess the probable duration of any delay. The Seventh Circuit affirmed, finding that the law did not impose that duty on the court and explained that when a defendant repeatedly refuses to cooperate with appointed counsel, the court may decline to appoint a new attorney and that the trial court can hold a defendant who elects to waive the right to counsel to that decision. (ST. EVE and JACKSON-AKIWUMI, concurring)