U.S. v. Campbell

In prosecution on drug distribution charges, Dist. Ct. did not err in denying defendant right to represent himself in violation of 6th amendment under circumstances where defendant initially requested either removal of his appointed counsel or allowance to proceed pro se, but then at subsequent hearing confirmed with Dist. Ct. that he was not going to represent himself. While Dist. Ct. failed to engage defendant in colloquy to address his request to represent himself, defendant failed to rebut Dist. Ct.'s observation at end of hearing that he interpreted defendant's response as indication that he did not want to represent himself. Accordingly, there was no 6th Amendment violation where there was no unequivocal waiver of right to counsel or no unequivocal demand to proceed pro se.