The Third Circuit vacated the defendant’s convictions and remanded for a new trial because the defendant sought to proceed pro se and the District Court did not conduct a sufficiently penetrating inquiry to satisfy itself that that the defendant could waive his right to counsel. The Third Circuit noted that the defendant was “difficult” and repeatedly pressed meritless legal arguments. In response to the defendant’s requests to proceed pro se, the District Court conducted a colloquy. The Court told the defendant that his understanding of legal principles was so “askew” that the defendant and the Court were “on very shaky grounds.” The Third Circuit held that the District Court should not have concerned itself as much with the defendant’s substantive knowledge, but rather with his understanding of the right he intended to waive.
