Case Explained: UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT UNITED STATES OF AMERICA v. LORIN KAL BUCKNER ) ) ) ) ) ) ) ) ) ) ) ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO

Court: United States Court of Appeals for the Sixth Circuit Filed: 2026-06-29 The Sixth Circuit affirmed Lorin Kal Buckner’s conviction on two counts of conspiracy to commit fraud and his sentence of 120 months imprisonment. The court held that Buckner’s waiver of his right to counsel was knowing and voluntary under *Faretta v. California*, noting that the district court’s colloquy satisfied the required model inquiry regarding the dangers of self-representation, the gravity of charges, and Buckner’s familiarity with the law. The court rejected Buckner’s argument that his use of “sovereign citizen” legal theories constituted a substantial change in circumstances requiring a new waiver assessment, stating that no degree of legal knowledge is required to waive counsel and that such fringe beliefs do not prove a defendant lacks understanding of the proceedings. Regarding competency, the court applied the standard under 18 U.S.C. § 4241(a) and found no “reasonable cause” to doubt Buckner’s capacity to understand the nature and consequences of the proceedings. Citing *United States v. Coleman*, the court ruled that idiosyncratic beliefs and unconventional legal arguments, even those characteristic of tax protesters or sovereign citizens, do not alone establish mental incapacity where the defendant demonstrates a rational understanding of the criminal process through other conduct, such as filing valid procedural motions and making a lucid closing argument. On sentencing, the court applied plain-error review to Buckner’s unpreserved challenges. It found no error in the district court’s failure to verify Buckner’s review of the presentence report under Federal Rule of Criminal Procedure 32, as Buckner could not show prejudice given the meritless nature of his objections to sentencing enhancements. The court also affirmed the application of a two-level enhancement for fraudulent action during a bankruptcy proceeding under U.S.S.G. § 2B1.1(b)(9)(B), reasoning that fraud persists through the proceeding, and upheld the leadership role enhancement under U.S.S.G. § 3B1.1(c) based on testimony regarding Buckner’s control over employees. Finally, the court dismissed Buckner’s challenge to his summary criminal contempt conviction for lack of jurisdiction, ruling that Federal Rule of Appellate Procedure 3(c)(1)(B) requires a notice of appeal to specifically designate the contempt order, which Buckner failed to do. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.