United States v. David Woods
137 F.4th 900
8th Cir.2025Background
- David Michael Woods was convicted by a jury of multiple counts of production, distribution, and possession of child pornography involving two minor boys in his care.
- Woods personally abused and exploited vulnerable foster and adopted children for years, including during the COVID-19 isolation period, and distributed child pornography.
- He initially retained counsel but then moved to represent himself; after a Faretta hearing, the court granted his motion and appointed standby counsel.
- The district court sentenced Woods to 1,200 months (100 years) of imprisonment, running sentences consecutively, and imposed a $2,500 assessment under the AVAA.
- Woods appealed his conviction and sentence, challenging the validity of his waiver of counsel, reasonable doubt instruction, trial court statements regarding his and a witness’s potential perjury, and imposition of the assessment.
Issues
| Issue | Woods's Argument | U.S. Argument | Held |
|---|---|---|---|
| Validity of Waiver of Counsel | Faretta hearing was insufficient; did not knowingly waive | Court properly explained risks; waiver valid | Waiver was knowing, intelligent, voluntary—affirmed |
| Jury Instruction on Reasonable Doubt | Court’s handling of objection misstated standard | Instruction tracked Eighth Circuit model | No plain error; instruction adequate |
| Court’s Statements on Potential Perjury | Court coerced him not to testify, violating constitutional right | Warnings were appropriate, not coercive | No plain error; judge’s statements not improper |
| Perjury Warning to Potential Witness | Court's warning chilled witness, violated right to defense | Warning appropriate given facts, filtered by counsel | No plain error; no evidence it caused witness silence |
| Imposition of Assessment under AVAA | Indigent, cannot pay $2,500 | He can earn in prison, negative net worth not dispositive | No clear error; assessment stands |
Key Cases Cited
- Faretta v. California, 422 U.S. 806 (1975) (constitutional right to self-representation and standards for waiver)
- Iowa v. Tovar, 541 U.S. 77 (2004) (no prescribed script required for valid waiver of counsel)
- United States v. True, 179 F.3d 1087 (8th Cir. 1999) (warnings about perjury must not be coercive or intimidating)
- Webb v. Texas, 409 U.S. 95 (1972) (trial court’s coercive warnings to potential witness can violate rights)