United States v. Williamson, 2017 U.S. App. LEXIS 9995

Background

Williamson was indicted on multiple child-pornography / enticement charges and faced life imprisonment.
After the federal public defender withdrew, the court appointed private attorney Robin Fowler; Fowler later moved to withdraw citing a breakdown in communication.
Fowler disclosed to the court that he was divorced from the Assistant U.S. Attorney (Kim Martin) who was prosecuting the case; Williamson later alleged that this co‑parenting relationship created a conflict of interest.
Williamson filed multiple pro se motions seeking new counsel, filed a criminal complaint against Fowler, and alleged a total breakdown in communications; the district court denied substitution motions.
On the morning of trial Williamson waived counsel after a Faretta colloquy, represented himself at trial and sentencing, was convicted on all counts, and sentenced to life.
Williamson appealed, challenging denial of substitute counsel, the validity of his Faretta waiver, and denial of his motion to suppress evidence seized under a search warrant.

Issues

Issue	Williamson's Argument	Government's Argument	Held
Whether the district court had a duty to inquire and must automatically reverse because Fowler had a personal relationship (former spouse, co‑parent) with the prosecutor	The court should apply Holloway’s automatic-reversal/duty-to-inquire principle beyond multiple-representation contexts because Fowler’s relationship posed a substantial risk of divided loyalty	Holloway’s automatic rule is limited to multiple/joint representation; Mickens/Cuyler control and require proof of an actual conflict unless the court was forced to accept joint counsel over timely objection	Holloway is limited to multiple representation; no automatic reversal. Because Williamson failed to show an actual conflict that affected performance, claim fails.
Whether filing a criminal complaint against counsel created a disqualifying conflict of interest requiring substitution	The complaint created counsel’s self-interest and impaired Fowler’s judgment, warranting substitution	Mere filing of a complaint does not automatically create an actual conflict; defendant must show counsel’s performance was adversely affected	Denial was not abuse of discretion; filing a complaint alone does not establish an actual conflict or prejudice.
Whether there was a complete breakdown in communication so as to require substitution of counsel	The conflicts and lack of trust constituted a total breakdown preventing adequate representation	Most disputes were strategic; the record shows meaningful communication was possible and Williamson substantially contributed to the breakdown	No abuse of discretion: disagreements were largely strategic and Williamson substantially and unreasonably contributed to communication problems.
Whether Williamson’s waiver of counsel and decision to proceed pro se was voluntary, knowing, and intelligent	Waiver was involuntary (a Hobson’s choice) because the court refused new counsel	Faretta waiver was voluntary and the court conducted a thorough colloquy warning of dangers and penalties; no coercion shown	Waiver was voluntary, knowing, and intelligent after adequate Faretta inquiry; decision to go pro se upheld.
Whether the search warrant and seizure should have been suppressed because the warrant/affidavit lacked a signature or the title "search warrant"	The warrant was facially defective: affidavit lacked affiant signature and the document did not explicitly bear the title "search warrant"	Fourth Amendment does not require hypertechnical facial markings; magistrate swore the affiant, judge signed warrant/affidavit, and practical accuracy suffices	Denial of suppression affirmed: omission of signature on affidavit and lack of the literal title did not render the warrant invalid under practical‑accuracy Fourth Amendment standards.

Key Cases Cited

Holloway v. Arkansas, 435 U.S. 475 (1978) (automatic reversal when court forces joint representation over timely objection)
Cuyler v. Sullivan, 446 U.S. 335 (1980) (no duty to inquire absent knowledge or reasonable cause to know of an actual conflict)
Mickens v. Taylor, 535 U.S. 162 (2002) (limits Holloway; automatic reversal confined to multiple-representation contexts)
Strickland v. Washington, 466 U.S. 668 (1984) (two‑prong ineffective-assistance standard: deficient performance and prejudice)
United States v. Cronic, 466 U.S. 648 (1984) (presumed prejudice when counsel is completely denied)
Faretta v. California, 422 U.S. 806 (1975) (right to self‑representation; waiver must be knowing and intelligent)
Groh v. Ramirez, 540 U.S. 551 (2004) (Fourth Amendment requires warrants to convey authority, but courts should avoid hypertechnical invalidation)