United States v. Michael Lawrence, Jr.

MEMORANDUM

Michael Jerome Lawrence, Jr., appeals his conviction for distribution of cocaine base. See 21 U.S.C. § 841 (a)(1). We affirm.

(1) Lawrence first argues that the district court erred when it granted his motion to-represent himself without first ascertaining that his waiver of his right to counsel was knowing and intelligent. See Faretta v. California, 422 U.S. 806, 835-36 , 95 S.Ct. 2525, 2541 , 45 L.Ed.2d 562 (1975); United States v. Farias, 618 F.3d 1049, 1051-52 (9th Cir.2010); United States v. Erskine, 355 F.3d 1161, 1167 (9th Cir.2004). We have reviewed the validity of the waiver de novo and disagree with Lawrence. While the district court did not use a particular form of advisal, there is no requirement that it do so. See United States v. Hayes, 231 F.3d 1132, 1138-39 (9th Cir.2000). The record shows that he was , adequately informed of the nature of the charges against him, and of the dangers and disadvantages of self-representation. Nothing in the record indicates that Lawrence did not understand that advice. See United States v. Neal, 776 F.3d 645, 658 (9th Cir.2015); United States v. Farhad, 190 F.3d 1097, 1098, 1100 (9th Cir.1999) (per curiam); see also…