Last week at the Tenth Circuit:
Waiver of Right to Counsel
When a person charged with a crime seeks to proceed pro se, the district court must ensure that the person's waiver of counsel is knowing and intelligent. Among other things, the district court must properly warn the person of the need to adhere to federal procedural and evidentiary rules. In United States v. Hansen, a tax-crimes prosecution against a sovereign citizen, the district court failed to do just this, rendering Mr. Hansen's waiver inadequate. Convictions and sentences vacated.
In United States v. Pittman (unpublished), the Tenth Circuit affirmed the district court's denial of Mr. Pittman's motion to suppress, reminding us along the way that the Federal Rules of Evidence do not apply at a suppression hearing.