No Denial of Defendant's Right to Represent Himself in Tax Case

US v. Miles, -- F.3d --, 2009 WL 2005250 (10th Cir. 7/13/09) - Mr. Miles was not denied his right to self-representation between the time the jury convicted him on nine counts of willfully filing false income-tax returns and his sentencing. He had represented himself at trial, then asked for his standby counsel to speak for him re: release after he was convicted. The district court reasonably believed that he waived his right to self-representation at that point and it allowed him to represent himself pro se when he asserted his right to do so at sentencing.