Fourth Circuit -- US v. Jimmy Hilton, Jr.

No clear error in trial court's holding that deft's description of her invocation of right to counsel was a bit more forthright than what actually happened, given police testimony to the contrary.

Where deft asks to go pro se at the beginning of jury selection and such a request risks undue delay, no clear error in deferring the shift to pro se representation to the beginning of the actual trial.

Federal identity theft statutes do not apply to those accused of 'stealing' a corporation's identity -- the use of 'person' and 'individual' is too ambiguous, given canon of lenity.

Where an employee has the authority to remove items from the company PO box, but does so with the intent of stealing something, the mail theft statutes apply.

Mailed invoices resulting in the checks to be stolen suffice for the mail fraud statute.

US v. Jimmy Hilton, Jr.