Rights to Counsel and Self-Representation Mutually Exclusive

US v. Beckton:  In this appeal, Reggie Andre Beckton challenged the district court’s rulings surrounding his representation at trial for two counts of bank robbery.  Prior to trial, two public defenders withdrew from representing Mr. Beckton, and he attempted to have a third disqualified; the district court denied this attempt, so Mr. Beckton elected to proceed pro se, despite repeated warnings from the court that self-representation was not in his best interest.  The district court permitted Mr. Beckton to have his court appointed counsel appear as standby; however, problems arose when Mr. Beckton decided to testify.  The district court ordered Mr. Beckton to either permit his standby counsel to assume control of the case, or he could present his testimony by questioning himself.  When Mr. Beckton opted to question himself, he testified in narrative form against the instructions of the district court.  Consequently, the district court limited his testimony.  Mr. Beckton repeated refused the assistance of counsel.  The jury convicted Mr. Beckton on both counts.

In matters of trial management, according to the Fourth Circuit panel, district courts enjoy wide discretion, and so long as restrictions are not “arbitrary or disproportionate to the purposes they are designed to serve,” a district court will not abuse its discretion.  The Fourth Circuit panel found the district court’s rationale “eminently reasonable” in preventing him from testifying in narrative form, and in requiring Mr. Beckton to adhere to substantive and procedural courtroom rules that all litigants must do, the district court was well within its discretion.