DISCLAIMER: Any unofficial case summaries below are prepared by the clerk's office
as a courtesy to the reader. They are not part of the opinion of the court.
063464P.pdf 06/06/2007 United States v. Tommie Crawford
U.S. Court of Appeals Case No: 06-3464
and No: 06-3465
and No: 06-3466
U.S. District Court for the District of Minnesota - St. Paul
[PUBLISHED] [Melloy, Author, with Bowman and Gruender, Circuit
Judges]
Criminal case - Criminal law. District court did not err in allowing
defendant to represent himself, and a competency hearing was not
required as there was no reasonable cause to believe he was not
competent; however, the court cannot conclude on the basis of this record
that defendant possessed the requisite knowledge of the challenges of
proceeding without counsel to have knowingly and intelligently waived
his right to counsel at sentencing; the error in allowing defendant to
proceed pro se at sentencing was harmless in this situation as the district
court imposed the minimum term of imprisonment allowed by the statute
and lacked authority to impose a more lenient sentence.