United States v. James Miller
2013 U.S. App. LEXIS 17838
| 8th Cir. | 2013Background
- Miller was convicted by a bench trial on four counts of making false claims against the United States under 18 U.S.C. § 287.
- The defense argued the district court should have renewed a Faretta inquiry at trial’s close.
- Miller initially sought self-representation, was found competent, and later represented himself with stand-by counsel.
- The court conducted two Faretta/competency hearings; Miller’s waiver to proceed pro se was found voluntary and knowing.
- Trial evidence showed Miller fabricated tax figures and filed sham financial instruments; closing remarks revealed no new exculpatory evidence; Miller chose not to testify.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Renewed Faretta inquiry required due to changed circumstances. | Miller asserts changed circumstances after closing argument. | District court did not err; no new facts necessitated renewal. | No renewed inquiry required; adequate warnings shown. |
| Sufficiency of the evidence to convict on false-claim counts. | Evidence proves Miller knew claims were false. | Miller believed his methods reflected truth; lack of intent shown. | Evidence sufficient; reasonable juror could convict. |
Key Cases Cited
- United States v. Tschacher, 687 F.3d 923 (8th Cir. 2012) (context for knowing and voluntary waiver of counsel)
- United States v. Turner, 644 F.3d 713 (8th Cir. 2011) (warning requirements for self-representation; dangers understood)
- United States v. Ladoucer, 573 F.3d 628 (8th Cir. 2009) (waiver of right to counsel need not include every possible defense)
- United States v. Kiderlen, 569 F.3d 358 (8th Cir. 2009) (scope of warnings needed for knowing and voluntary waiver)