102524P.pdf   07/12/2011  United States  v.  Samuel Turner
   U.S. Court of Appeals Case No:  10-2524
   U.S. District Court for the Eastern District of Missouri - Cape Girardeau   
   [PUBLISHED] [Benton, Author, with Riley, Chief Judge, and
   Shepherd, Circuit Judge]
   Criminal case - Criminal law. Defendant's waiver of counsel was
   voluntary, knowing and intelligent, and the district court did not err in
   finding he was mentally competent to make the decision and proceed pro
   se; court did not clearly err by failing to sua sponte order a competency
   hearing after observing defendant's behavior at trial; defendant received
   the minimum possible sentence, and any error in failing to order a
   competency review for sentencing was harmless, as the court could not
   have imposed a more lenient sentence than the mandatory minimum.