United States v. Huwell Craig, (Three Cases)

996 F.2d 1228 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. UNITED STATES of America, Plaintiff-Appellee, v. Huwell CRAIG, Defendant-Appellant. (Three Cases) Nos. 91-50778, 91-50787 and 91-50789. United States Court of Appeals, Ninth Circuit. Argued and Submitted May 5, 1993. Decided June 30, 1993. Before: KOZINSKI, SUHRHEINRICH, * and T.G. NELSON, Circuit Judges. 1 MEMORANDUM ** 1. Sixth Amendment Right to Counsel 2 "[T]he sixth amendment is violated whenever the accused is denied counsel at a critical stage of his trial." United States v. Bohn, 890 F.2d 1079, 1080 (9th Cir.1989) (quotations omitted). " 'Critical stages of the prosecution include all parts of the prosecution implicating substantial rights of the accused.' " Id. (quoting Menefield v. Borg, 881 F.2d 696, 698 (9th Cir.1989) (emphasis added)). The Supreme Court has found three factors useful in determining when the event constitutes a critical stage: (1) " 'if failure to pursue strategies or remedies…