U.S. v. Williams

In prosecution on drug distribution and unlawful possession of firearms charges, Dist. Ct. abused its discretion in failing to inquire into defendant's concerns about his counsel when defendant attempted to raise mid-trial issue regarding his counsel's failure to apprise defendant of certain video evidence. Said failure improperly stifled any attempt by defendant to request new attorney or to proceed pro se. However, said error was harmless where defendant failed to show that his counsel was incompetent, and record otherwise demonstrated that counsel was familiar with all video recordings. Moreover evidence of defendant's guilt, in terms of video recordings of controlled drug purchases and defendant's inculpatory statements, was overwhelming.