United States v. Ronnie Fields

Fields appeals from his conviction for conspiracy to commit armed bank robbery, in violation of 18' U.S.C. §§ 371 and 2113(a)(d), and for aiding and abetting armed bank robbery, in violation of 18 U.S.C. §§ 2 and 2113(a)(d). He argues that the trial court’s refusal to authorize an additional $1,250 for defense investigation work so prejudiced his defense that his conviction must be reversed. The government responds that we lack jurisdiction over the appeal and, in the alternative, that the conviction should be affirmed on the merits. We hold that we have jurisdiction over the appeal and affirm.

18 U.S.C. § 3006A authorizes district courts to provide funds to ensure that defendants receive representation. Provisions for appointment and payment of counsel appear in subsections 3006A(a)-(d). Subsection 3006A(e), which is the subsection at issue in this case, allows allocation of funds for “investigative, expert, or other services necessary for an adequate defense.” Defense counsel may request funds for these services in an ex parte application, 18 U.S.C. § 3006A(e)(l), and a district court may grant funds over the statutory maximum amount with the approval of the chief judge of the…