US v. Roof: In 2015 Roof went to a bible study meeting at a Emanuel African Methodist Episcopal Church in Charleston, SC. At the end of the meeting he pulled out a gun and started shooting, killing nine and wounding others. He was eventually charged with numerous federal offenses related to the shooting that made him eligible for the death penalty. After a jury trial where he was represented by counsel, Roof was convicted on all counts. After a sentencing phase where he represented himself, Roof was sentenced to death.
On appeal, a not-quite-Fourth Circuit panel affirmed Roof’s convictions and death sentence in a 149-page opinion.* In addition to numerous issues related specifically to the death penalty, the court also addressed issues related to Roof’s competency and ability to represent himself during the sentencing phase of proceedings. Overall, the court found no abuse of discretion in the district court’s decisions that Roof was competent (made both before trial and between the guilt and penalty phases) or that he was competent to represent himself during the sentencing phase. Threaded through both decisions was a conflict between Roof and counsel about presenting mental health evidence at sentencing, with Roof fearing that such an argument was overtake the political aspect of his actions.
* Because Judge Richardson was the United States Attorney in South Carolina when Roof was prosecuted, all the judges of the Fourth Circuit recused themselves and judges from the Eighth, Sixth, and Third Circuits heard the appeal.