United States v. J. Bravo-Mendoza

MEMORANDUM

Bravo-Mendoza’s waiver of counsel complied with Faretta v. California, 422 U.S. 806, 835 , 95 S.Ct. 2525 , 45 L.Ed.2d 562 (1975). He was advised of, and acknowledged that he understood, the charges, potential sentence, and risks of self-representation. United States v. Forrester, 512 F.3d 500, 506-07 (9th Cir.2008).

Indiana v. Edwards, 554 U.S. 164, 177-78 , 128 S.Ct. 2379 , 171 L.Ed.2d 345 (2008), does not require that a district court conduct a hearing to determine whether a defendant who is competent to stand trial is also competent to represent himself at trial. Rather, Edwards permits the trial court to deny a defendant his constitutional right to self-representation if the defendant is so severely mentally ill that he is unable to carry out the basic tasks necessary for self-representation. See United States v. Thompson, 587 F.3d 1165, 1171-72 (9th Cir.2009); United States v. Ferguson, 560 F.3d 1060 , 1070 n. 6 (9th Cir.2009). Despite Bravo-Mendoza’s odd comments, the record establishes that he was able to represent himself. He made peremptory challenges during voir dire, cross-examined witnesses, presented a defense, introduced documents, testified, made a…