Percy Leroy Jacobs v. United States
JusticiabilityDoctri
I. Whether, for a waiver of the Sixth Amendment right to trial counsel to be effective, a defendant must understand the elements of the charged offenses – as part of the defendant's understanding of the "nature of charges," Von Moltke v. Gillies, 332 U.S. 708, 724 (1948) (plurality op.)); cf. Bradshaw v. Stumpf, 545 U.S. 175, 183 (2005) ("Where a defendant pleads guilty to a crime without having been informed of the crime's elements, th[e] [due process] standard is not met and the plea is invalid.")
II. Whether a trial judge must provide unambiguous information about the maximum criminal penalties that a defendant faces upon conviction before accepting the defendant's waiver of his right to trial counsel.
III. Whether a trial judge must address the factors set forth in the plurality opinion in Von Moltke, supra, in a waiver colloquy in order for a defendant's waiver of the Sixth Amendment right to counsel to be valid.
IV. Whether the district court violated the Speedy Trial Act.
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