U.S. v. Smith

Defendant pleaded guilty to one count of conspiracy to distribute methamphetamine and one count of money laundering. Shortly before his sentencing hearing, defendant filed a motion to substitute counsel, which the district court denied. Defendant then appealed from both the district court’s denial of his request for substitute counsel and the substantive reasonableness of his sentence, which was below federal sentencing guidelines. The Seventh Circuit affirmed, finding that the district court did not abuse its discretion in denying the motion of counsel to withdraw and that defendant’s sentence was not unreasonable. (EASTERBROOK and JACKSON-AKIWUMI, concurring)