Defendant Competent to Stand Trial Is Competent to Proceed Pro Se

US v. Snyder: Snyder was “a prominent Maryland attorney” for “nearly fifty years.” While representing kidney transplant patients in a suit against a Maryland hospital, he “developed a scheme in which he threatened to run a targeted advertising campaign against” the hospital “unless it agreed to pay him, personally, $25 million.” He would be a “consultant” to the hospital and, therefore, conflicted out of any future litigation against them. He represented himself at trial, in spite of several medical issues (a Parkinson’s diagnosis, a fall in the bathroom during a recess, etc.), refusing to do otherwise after questioned on multiple occasions. He was convicted of attempted extortion and other charges at trial. 

On appeal, the Fourth Circuit affirmed Snyder’s convictions, rejecting several of his challenges. First, the court held that there was no error in the district court not sua sponte revoking Synder’s right to represent himself. When Snyder’s counsel at oral argument conceded “that he was competent to stand trial at every stage of the proceedings against him” that was “fatal to his appeal of this issue,” as the court had previously held that “a defendant who is competent to stand trial is necessarily competent to waive his right to counsel.” And while the district court could have revoked Snyder’s right to proceed pro se it was not required to do so. Second, the court held there was no error in not giving a jury instruction that Snyder relied on the advice of counsel in proposing the consultancy because he had not shared the entire scheme with the attorney he consulted. Third, the court found no abuse of discretion in how the district court limited one witness’ testimony, given the non-disclosure agreement she signed related to her case against the hospital. Finally, the court held there was no error in the district court not conducting voir dire with the jury about whether they saw any news coverage of Snyder’s mid-trial contempt proceeding, given already given instructions about avoiding media coverage of the case.