Background

• Romero-Trejo was convicted of one count of conspiracy to commit hostage taking and received a within-guidelines sentence of 240 months plus five years of supervised release.
• On appeal, Romero-Trejo challenges district court rulings denying substitute counsel and denying a continuance, raised in a pro se sentencing-letter not in the appellate record.
• Romero-Trejo argues his right to a complete appellate record was violated by the district court’s failure to admit the letter into the record.
• The record shows the district court properly addressed his claims and the substance of the letter can be ascertained from the record.
• The court held that the letter’s omission did not deny effective appellate review and Romero-Trejo had some responsibility for not providing a copy.
• The court concluded the district court did not abuse its discretion in denying substitute counsel or in denying a continuance, and noted the sentence remained within guidelines.

Issues

Key Cases Cited

• United States v. Margetis, 975 F.2d 1175 (5th Cir. 1992) (missing trial transcripts not letters; effective appellate review)
• United States v. Neal, 27 F.3d 1035 (5th Cir. 1994) (effective appellate review considerations)
• United States v. Fields, 483 F.3d 313 (5th Cir. 2007) (inquiry into counsel effectiveness sufficient to determine issues)
• United States v. Young, 482 F.2d 993 (5th Cir. 1973) (conflict of interest and unjust verdict considerations)
• United States v. Simpson, 645 F.3d 300 (5th Cir. 2011) (discretionary decisions about counsel)
• United States v. Stalnaker, 571 F.3d 428 (5th Cir. 2009) (prejudice and continuance standards)
• United States v. Barnett, 197 F.3d 138 (5th Cir. 1999) (within-guidelines sentence and discretion)