United States v. Massey, __ F.3d __ (9th Cir. 2005) ("Massey attempted to hinder his trial by declining every constitutionally recognized form of counsel while simultaneously refusing to proceed pro se. A defendant may not abuse the Sixth Amendment in this way: tactics such as those employed by Massey amount to an unequivocal waiver of the right to counsel. United States v. Kienenberger, 13 F.3d 1354, 1356 (9th Cir. 1994); United States v. Hardy, 941 F.2d 893, 896-97 (9th Cir. 1991)."

jurisdiction: 
Ninth Circuit

 

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