United States v. Taylor
2011 U.S. App. LEXIS 18026
| 8th Cir. | 2011Background
- Taylor robbed the Central Bank of Kansas City, taking $2,700 in cash after sliding a threatening note to a teller.
- Video footage and DNA linked Taylor to the store where he fled and to a green hat found with the jacket and cash.
- Evidence at trial supported conviction for bank robbery under 18 U.S.C. § 2113(a).
- Taylor repeatedly moved for new appointed counsel and challenged counsel’s effectiveness before trial.
- The district court conducted multiple hearings, rejected requests for substitute counsel, and ultimately allowed Taylor to proceed pro se with standby counsel available.
- Taylor was convicted and the district court’s denial of substitute counsel and acceptance of self-representation were appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion denying substitute counsel | Taylor argues persistent dissatisfaction warranted new counsel | Taylor's dissatisfaction stemmed from communication breakdowns with Poindexter | No abuse; no justifiable dissatisfaction shown |
| Whether Taylor's waiver of counsel was knowing and voluntary | Waiver occurred after attempts to obtain new counsel were refused | Waiver valid given competent counsel and uncooperative behavior | Waiver valid; proceeding pro se affirmed |
| Whether the court properly handled self-representation warnings | Warnings were insufficient about risks of self-representation | Court properly cautioned and ensured understanding of consequences | Warnings adequate; waiver valid under Faretta framework |
Key Cases Cited
- United States v. Barrow, 287 F.3d 733 (8th Cir. 2002) (requires adequate inquiry into breakdown in attorney-client communications)
- United States v. Swinney, 970 F.2d 494 (8th Cir. 1992) (right to counsel not the right to a meaningful relationship with counsel)
- United States v. Exson, 328 F.3d 456 (8th Cir. 2003) (quality of advocacy governs justifiable dissatisfaction with counsel)
- Faretta v. California, 422 U.S. 806 (1985) (competence of self-representation requires knowing and voluntary waiver)
- United States v. Mentzos, 462 F.3d 830 (8th Cir. 2006) (waiver valid if counsel competent and no good cause for appointment)