Arteaga-Giron

MEMORANDUM *

Edgar William Arteaga-Giron appeals his conviction for conspiracy to distribute and possession of 500 or more grams of methamphetamine, and carrying and for possessing a firearm in furtherance of a drug trafficking crime. Arteaga-Giron claims the trial court erred in denying his request to represent himself. See Faretta v. California, 422 U.S. 806 , 95 S.Ct. 2525 , 45 L.Ed.2d 562 (1975).

Standard of Review

This circuit has “not yet clarified whether denial of a Faretta request is reviewed de novo or for abuse of discretion.” United States v. Kaczynski, 239 F.3d 1108, 1116 (9th Cir.2001); see also United States v. George, 56 F.3d 1078, 1084 (9th Cir. 1995). In both Kaczynski and George , this court declined to rule on this issue, finding that under either standard the result would be the same. Kaczynski, 239 F.3d at 1116 ; George, 56 F.3d at 1084 . Today, we again decline ruling on the issue because the result is the same under either standard.

Merits

The Sixth Amendment guarantees a defendant the right of self-representation. Faretta, 422 U.S. at 834 . “A defendant may not invoke the Faretta right if the Faretta demand is untimely, equivocal, made for the purpose…