Published on: Thursday, December 30, 2021

A drug defendant is entitled to a new trial because he was improperly denied his right to represent himself, the Third Circuit ruled.

When it denied Donte Taylor’s request, the trial court focused on motions he filed, characterizing them as “convoluted” and “just a waste of time.” The judge also told Taylor he wasn’t going to let him turn the trial “upside-down.”

Although the trial judge spoke with Taylor before saying he couldn’t represent himself, he erred by not insuring that Taylor understood the nature of the charges against him, the range of possible punishments, and the risks of self-representation, the court said. The judge simply failed to adequately investigate Taylor’s request, it said.

Taylor was convicted of possession with intent to distribute controlled substances and sentenced to 22 years in prison.

The case is United States v. Taylor, 20-3158 (3d Cir. Dec. 21, 2021).