Sixth Circuit -- USA v. Bryan Ross

Given prior abuse of attorney process and prior colloquy, trial court correctly allowed deft to proceed pro se after minimal colloquy.

Deft has a constitutional, non-waiveable right to counsel at competency hearing, even where court has legitimately allowed him or her to proceed pro se to that point.

Standby counsel did not provide meaningful adversarial testing of the case against deft.

As competency hearing is a critical stage, vacation and reversal is required for denial of counsel.

No abuse of discretion in allowing polygraph agreement into evidence.

No Speedy Trial Act claim, as not in bad faith.

No abuse of process in denial of subpoena

A few other things, including a 

Dissent.



USA v. Bryan Ross