Motion for self-representation is timely if made before jury impaneled

SELF-REPRESENTATION United States v. Tucker No. 05-3259, ___ F.3d ___ (10th Cir. Jun. 28, 2006)(Kansas). Appeal of conviction for being felon in possession of ammunition in violation of 18 U.S.C. §§ 922(g)(1) and 924(a)(2). HELD: District court erred by not permitting defendant to represent himself during voir dire. Motion for self-representation made six days before trial is not per se untimely. Unless used as tactic for delay, motion for self-representation is timely if made before jury impaneled. Read the opinion here.