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OMAR RASHAD POUNCY,
Petitioner-Appellee,
v.
CARMEN DENISE PALMER, Warden,
Respondent-Appellant.
   No. 16-1137
Appeal from the United States District Court
for the Eastern District of Michigan at Detroit.
No. 2:13-cv-14695—Matthew F. Leitman, District Judge.
Argued: August 4, 2016
Decided and Filed: January 13, 2017
Before: BOGGS, CLAY, and SUTTON, Circuit Judges.


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OPINION
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BOGGS, Circuit Judge. It is well established that the Constitution guarantees criminal defendants the right to self-representation. Faretta v. California, 422 U.S. 806, 832 (1975). But because an accused who manages his own defense relinquishes many of “the traditional benefits associated with the right to counsel,” courts must ensure that a defendant who wishes to represent himself does so “knowingly and intelligently,” and the record must “establish that ‘he knows what he is doing and [that] his choice is made with eyes open.’” Id. at 835 (quoting Adams v. United States ex rel. McCann, 317 U.S. 269, 279 (1942)). Facing a jury trial on charges related to two Michigan carjackings, eighteen-year-old Omar Pouncy waived his right to counsel. This habeas appeal concerns whether he did so voluntarily. After a Michigan jury convicted Pouncy on all charges, he unsuccessfully sought relief in the state court system. Pouncy then petitioned the district court to vacate his convictions on the ground that the state trial court forced him to choose between going to trial with an unprepared attorney and representing himself. The district court concluded that Pouncy faced a “Hobson’s choice” and that his waiver of counsel was therefore involuntary. The district court granted Pouncy the writ and the Warden appealed. Because the highly deferential standards applicable to federal collateral review of state-court convictions direct a different result, we reverse.



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UNITED STATES OF AMERICA,
Plaintiff-Appellee,
v.
SANDRA MAXINE WHITE,
Defendant-Appellant.
   No. 15-2234
Appeal from the United States District Court
for the Western District of Michigan at Grand Rapids.
No. 1:13-cr-00222—Paul Lewis Maloney, District Judge.
Argued: December 1, 2016
Decided and Filed: January 13, 2017
Before: MOORE and CLAY, Circuit Judges; HOOD, District Judge.


_________________________
OPINION
_________________________

KAREN NELSON MOORE, Circuit Judge. Sandra White (“White”) and her husband Joseph White operated a travel agency. In order to obtain low airline fares for the agency’s clients, White routinely booked military-rate travel for her non-military-member clients. When airlines became suspicious of White’s practices, and asked her for proof of her clients’ military status, White manufactured fake military identification cards and sent them to the airlines as alleged proof of her clients’ military credentials. The airlines suspected that the military identification cards were forged and contacted investigators. After a jury trial, White was convicted of mail fraud and aggravated identity theft, and sentenced to a total of ninety-four months of imprisonment.

White now challenges her conviction and sentence on the basis that (1) the district court read an improper definition of the term “use” into the aggravated identity theft statute; (2) the district court abused its discretion in refusing to admit certain evidence of White’s intention to repay some of the airlines’ losses; and (3) the district court erred in calculating the amount of White’s victims’ losses. For the reasons set forth below, we AFFIRM the judgment of the district court.