Epstein Secrets

cond Circuit. UNITED STATES America, Appellee, Donald FELL, Defendant-Appellant. Docket No. 06-2882-cr

based on the fact that the govern- ment presented evidence that de- fendant was a member of a gang that had committed violen and un- lawful acts); Wainwright . Lock- hart, 80 F.3d 1226, 1 4 (8th Cir.1996) (ruling that questioning of defendant on involvement in street gang "did not serve any prop- er reb

83, 86 (1963) (holding prosecution's withholding of the confession of defendant's confederate violated defendant's due process rights). 7 Gideon v. Wainwright, 372 U.S. 335, 342 (1963) (extending Sixth Amendment right to assistance of counsel to indigent state criminal defendants); Powell v. Alabama, 287 U.

d explaining how insufficient data limits the effectiveness of reform efforts). On the prospect of reduced federal commitment to this strategy in the Trump administration, see U.S. Attorney Gen., supra note 24; Horwitz et al., supra note 24. 197 See Dripps, supra note 149, at 19 & n.100 (citing five fed

d go without saying that nothing in the Rules can trump a substantive statute passed by Congress. See 28

ermits the court in both civil and criminal cases to "request an attorney to represent any person unable to afford counsel." 49° And before Gideon v. Wainwright, *°° courts could request 45 Td. 46 Td. 47 Tn possible response to such concerns as I raise here, the Advisory Committee modified the Advisory Comm

s can modify substantive rights, °° the CVRA will trump any conflicting provision in the federal rules. °

nd criminal cases. 3!! While these cases do not directly involve [*913] appointment of counsel for crime victims, their principles 309 Cf. Gideon v. Wainwright, 372 U.S. 335, 344 (1963) (discussing "fairness" to the defendant as a reason for recognizing a right to appointed counsel). 310 150 Cong. Rec. S426