United States v. Rick Paul Springer

Rick Paul Springer was convicted of failing to surrender for the service of his sentence for a previous crime. See 18 U.S.C. § 3146 (a)(2). He represented himself and now claims that he was not properly questioned about his waiver of counsel. He also asserts that the district court erred in its rulings regarding his defense, which was, in effect, that because of his opposition to nuclear bomb testing he could not report. We affirm.

BACKGROUND

Springer, who was opposed to nuclear bomb testing, felt called upon to interfere with a ceremony where former President Ronald Reagan was receiving a gift of a crystal eagle. Springer destroyed the eagle because he thought that would be an appropriate way to call attention to a nuclear bomb test scheduled for the next day. As a result, he was convicted of interference with the Secret Service and was sentenced to 120 days of incarceration for that offense. See 18 U.S.C. § 3056 (d). He was ordered to surrender on April 2, 1993, but that date was later extended to June 2, 1993.

Springer determined that he would not surrender because something more important held his attention. He was concerned that a moratorium on nuclear testing was about to…