Background
Michael Thomas pled guilty to possessing a stolen firearm and was sentenced to one hundred twenty months in prison. Before sentencing, Thomas sent a pro se letter expressing concerns about his counsel, though the letter was not included in the appellate record. At the sentencing hearing, the district court questioned Thomas about his dissatisfaction and whether he wanted to substitute counsel.
The court’s reasoning
The Sixth Circuit explained that while the Sixth Amendment right to counsel attaches at sentencing, a defendant must show good cause for substitution. The court found that Thomas’s oral statements to the district court, where he affirmed his current counsel could represent him and declined to request new counsel, meant the district court did not err in proceeding. Additionally, the court applied the invited-error doctrine, noting that Thomas’s own actions and statements invited the court to move forward, and no manifest injustice resulted from declining to review the matter.
What it means going forward
This decision reinforces that defendants who affirmatively state they are satisfied with their counsel and wish to proceed with sentencing cannot later claim on appeal that the court failed to conduct a fuller inquiry into their representation.