Case Explained: UNITED STATES OF AMERICA v. KENYADA JAQU

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-07-27 The fourth-circuit vacated the judgment and remanded the case for resentencing because the district court erroneously denied the defendant’s Sixth Amendment right to self-representation at sentencing. The court held that a request to proceed pro se made after a trial verdict but before a sentencing hearing is timely as a matter of law, provided it is clear, unequivocal, knowing, intelligent, and voluntary. The appellate court reasoned that unlike requests made during an ongoing trial which risk disruption, a pre-sentencing request does not implicate the same concerns regarding delay or inconvenience because there is typically a substantial period between conviction and sentencing to address such motions without prejudice. Consequently, the district court’s reliance on the “untimeliness” of the request—based solely on the fact that it was made months after the trial concluded but before sentencing was scheduled—constituted legal error. The court further noted that the deprivation of the right to self-representation is not subject to harmless error analysis, necessitating a remand for a new sentencing hearing where the district court must conduct a full *Faretta* inquiry to determine if the defendant’s waiver of counsel was valid. The court declined to address the defendant’s separate argument regarding an Armed Career Criminal Act enhancement. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.