Eleventh Circuit Announces Sixth Amendment Right to Proceed Pro Se at Sentencing if Defendant ‘Clearly and Unequivocally’ Expresses Desire to Do So After Faretta Inquiry

The United States Court of Appeals for the Eleventh Circuit held that the defendant had clearly and unequivocally asserted his Sixth Amendment right to self-representation at sentencing, which imposed a constitutional duty on the U.S. District Court for the Southern District of Florida to conduct a Faretta inquiry and that …