United States v. Patrick Longsworth, 23-13692

Patrick Longsworth was charged with three counts of aiming a laser pointer at aircraft (Coast Guard and police helicopters), facing potential five-year sentences per count.
The government offered a pretrial-diversion program to resolve the case without conviction, which Longsworth refused, leading to conflicts with his court-appointed attorneys.
Following continued disagreements, Longsworth chose to represent himself, and the district court conducted a Faretta inquiry to determine if his waiver of his right to counsel was knowing and voluntary.
Despite expressing some concerns about his mental state, the district court found Longsworth competent to represent himself and allowed him to proceed pro se, with standby counsel available.
At trial, Longsworth essentially did not mount a defense and was convicted on all counts; after trial, new counsel moved for a competency hearing, which was denied.
Longsworth appealed, arguing that his waiver of counsel was invalid due to alleged severe mental illness.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the waiver of counsel knowing and voluntary?	Longsworth: Mentally ill and unable to adequately waive counsel; conduct at trial proved incompetency.	Government: Faretta inquiry established knowing and voluntary waiver; no evidence of incompetency.	Waiver was knowing and voluntary; conviction affirmed.
Did the court err by conflating competency to stand trial and competency to waive counsel?	Longsworth: Court applied wrong standard, relying only on trial competency.	Government: Full Faretta inquiry conducted; standards properly explained and applied.	Any error harmless; correct Faretta standard used in practice.
Was a structural error committed by allowing self-representation?	Longsworth: Severe mental illness rendered self-representation invalid regardless of inquiry.	Government: No diagnosed or evident mental illness; respectful and responsive throughout proceedings.	No structural error; court's decision affirmed.
Should post-trial motion for competency hearing have been granted?	Longsworth: Mental health concerns warranted competency hearing after trial.	Government: No demonstrated incompetency at trial; post-trial behavior did not justify hearing.	Denial of competency hearing affirmed.

Faretta v. California, 422 U.S. 806 (1975) (established the constitutional right of criminal defendants to self-representation, requiring waivers of counsel to be knowing and intelligent)
United States v. Hakim, 30 F.4th 1310 (11th Cir. 2022) (standard for reviewing waivers of counsel and appellate standards)
United States v. Garey, 540 F.3d 1253 (11th Cir. 2008) (en banc) (validity of waiver and standards for uncooperative defendants)
United States v. Owen, 963 F.3d 1040 (11th Cir. 2020) (eight-factor test for knowing and voluntary waiver of counsel)
United States v. Muho, 978 F.3d 1212 (11th Cir. 2020) (Faretta right is protected despite likely downsides to self-representation)
Kimball v. State, 291 F.3d 726 (11th Cir. 2002) (legal knowledge not required for valid Faretta waiver)