United States v. Robert Tringham

MEMORANDUM

Robert Tringham appeals his conviction on several grounds: that the district court abused its discretion in denying his motions for substitution of counsel and for a continuance, that his Faretta waiver was invalid because it was coerced by the court’s denial of his motions to substitute counsel, that cumulative error violated his right to due process, that the court did not adequately inquire into a witness’s invocation of his Fifth Amendment right against self-incrimination, and that insufficient evidence supported his conviction on two counts. We have jurisdiction under 28 U.S.C. § 1291 , and we affirm.

The district court did not abuse its discretion in finding that Tringham “failed to establish any conflict that would require the Court to substitute new counsel.” The court questioned Tringham and his attorney “ ‘privately and in depth’ ” about the issues Tringham raised. United States v. Nguyen, 262 F.3d 998, 1004 (9th Cir.2001) (citation omitted). The disagreement between Tringham and his attorney was over strategy, and “[i]t is well-settled ... that this type of dispute is not a sufficient conflict to warrant substitution of counsel.” United States v. McKenna,…