United States v. Reggie Beckton
740 F.3d 303
4th Cir.2014Background
- Beckton was convicted on two counts of bank robbery under 18 U.S.C. § 2113(a).
- The district court appointed three public defenders; Beckton alleged conflicts and personality clashes.
- A fourth attorney was not appointed; Beckton moved to disqualify the third attorney and requested trial postponement, which were denied.
- Beckton chose to proceed pro se with standby counsel, Manning, after warnings about the advisability of self-representation.
- At trial, Beckton sought to testify in narrative form; the court required testimony in question–answer format to allow objections, and Beckton testified narratively, causing a jury-removal and final ruling on his testimony.
- Beckton was convicted after the jury was recalled for closing arguments; he timely appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Narrative testimony vs. Q&A format | Beckton contends narrative form should be allowed. | Court may require question–answer format to allow objections. | No abuse; court properly limited narrative testimony to protect objections. |
| Right to testify vs. self-representation conflict | Beckton argues he was forced to choose between rights. | Rights can be exercised simultaneously; no forced choice. | Not compelled to choose between two protected rights; proper procedure followed. |
| Standby counsel versus pro se control | Beckton wanted standby counsel to question him while he pro se. | Court may deny hybrid arrangements; standby cannot be used to circumvent rules. | Court within discretion to reject hybrid arrangement; Beckton could not question himself with standby counsel controlling testimony. |
Key Cases Cited
- Faretta v. California, 422 U.S. 806 (U.S. 1975) (self-representation and limitations on procedure)
- Rock v. Arkansas, 483 U.S. 44 (U.S. 1987) (limits on right to testify to protect truth-finding process)
- McKaskle v. Wiggins, 465 U.S. 168 (U.S. 1984) (standby counsel cannot undermine defendant's control of defense)
- Midgett v. United States, 342 F.3d 321 (4th Cir. 2003) (right to testify vs. right to counsel distinction; not applicable where rights are not jointly restricted)
- United States v. Lawrence, 161 F.3d 250 (4th Cir. 1998) (court has broad discretion to guide assistance to self-represented defendants)