Cohen
United States v. Cohen
Opinion
Lead Opinion
MEMORANDUM **
Leslie Charles Cohen appeals his jury conviction for bank fraud and related charges. He argues that his Sixth Amendment right to self-representation was violated because he was deprived of food, sleep, and law library access during his trial, and that the district court violated his right to equal protection by denying his request for a free transcript of a mistrial for impeachment purposes. He also challenges the lawfulness of a search warrant executed on his home.
We review de novo whether a defendant’s right to self-representation was violated. See United States v. Sarno, 78 F.3d 1470, 1491 (9th Cir.1995). If the district court’s discretion is implicated, we review for an abuse of discretion, and we review any underlying findings of fact for clear error. United States v. Mateo-Mendez, 215 F.3d 1039, 1042 (9th Cir.2000). We also review de novo the district court’s denial of a motion to suppress evidence, United States v. Meek, 366 F.3d 705, 711 (9th Cir.2004), and whether the district court erred by refusing to provide appellant with a free transcript of the prior proceeding. United States v. Kirk, 844 F.2d 660, 662 (9th Cir.1988).