United States v. Davon Hammond, 22-4606

Davon Hammond pled guilty to two federal charges: (1) possession of a firearm and ammunition by a felon, and (2) assault causing substantial bodily injury to an intimate partner within special federal jurisdiction.
Hammond represented himself after waiving his right to counsel.
He later challenged his conviction both on the validity of his waiver of counsel and the voluntariness of his guilty plea.
Hammond also sought to withdraw his guilty plea, arguing it was not knowing and voluntary.
The district court found Hammond's waiver and plea valid, and denied his motion to withdraw the plea.
Hammond appealed these rulings to the Fourth Circuit.

Issue	Hammond's Argument	Government's Argument	Held
Validity of Waiver of Counsel	Waiver was not knowing, intelligent, and voluntary due to lack of understanding of charges	Waiver was knowing, voluntary, and Hammond was competent	District court did not err; waiver valid
Voluntariness of Guilty Plea	Plea not knowing/voluntary; did not understand charges (Rule 11 violation)	District court fully complied with Rule 11; plea knowing and voluntary	District court did not err; plea valid
Denial of Motion to Withdraw Guilty Plea	District court abused discretion; did not consider all factors	District court properly considered all relevant factors	District court did not abuse discretion

Faretta v. California, 422 U.S. 806 (right to self-representation under the Sixth Amendment)
United States v. Vonn, 535 U.S. 55 (requirements for a valid guilty plea under Rule 11)
United States v. Moore, 931 F.2d 245 (factors for withdrawal of a guilty plea)
United States v. Bush, 404 F.3d 263 (waiver of right to counsel evaluated on full record)
United States v. Bernard, 708 F.3d 583 (competence required for waiver of counsel is competence to stand trial)