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Criminal Law : Supervised Release – Revocation Hearing – Self Representation

Stephanie Maniscalco//May 12, 2017//

Criminal Law : Supervised Release – Revocation Hearing – Self Representation

Stephanie Maniscalco//May 12, 2017//

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Where a defendant argued that the district court violated his Sixth Amendment right to counsel by allowing him to proceed pro se at his revocation hearing, the Sixth Amendment right to counsel applies only to criminal proceedings, and a revocation hearing is a different type of proceeding, and under the totality of the circumstances, the defendant voluntarily, knowingly and intelligently choose to represent himself at the hearing.

Judgment is affirmed.

U.S. v. Owen (MLW No. 70438/Case No. 16-2521 – 13 pages) (U.S. Court of Appeals, 8th Circuit, Riley, C.J.) Appealed from U.S. District Court, Western District of Missouri, Bough, J. (Erica Mynarich, Springfield, argued for appellant) (Ami Harshad Patel Miller, Springfield, argued for appellee).

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