## Facts

- A federal grand jury indicted Reggie Andre Beckton on two counts of robbing federally insured banks in Wilmington, North Carolina, in violation of 18 U.S.C. § 2113(a).
- Before trial, the district court appointed three different public defenders; the first two withdrew after Beckton asserted “conflicts” and made inappropriate remarks.
- One week before trial, Beckton moved to disqualify his third appointed attorney and sought a continuance; the court found no genuine conflict and denied both requests.
- Beckton chose to represent himself; the court warned him about the risks, required compliance with rules of evidence and procedure, and appointed counsel as standby.
- On the first day of trial, the court again instructed Beckton on procedure and warned that outbursts and improper comments would not be tolerated.
- During trial, Beckton repeatedly attempted to present inadmissible material and improper argument, including in his opening statement.
- After the government rested, Beckton stated he wanted to testify; outside the jury’s presence, the court ruled he could not testify in narrative form and would have to proceed by question-and-answer.
- The court offered Beckton two options: standby counsel could question him, or the court would conduct questioning in a structured format without standby counsel.
- Beckton refused both options and insisted on narrative testimony; the court found he had elected not to testify.
- A jury convicted Beckton on both robbery counts, and he appealed.

## Issues

1. Whether refusing to allow a pro se defendant to testify in narrative form violated the defendant’s constitutional right to testify or was an abuse of discretion.
2. Whether requiring question-and-answer testimony (including permitting standby counsel to question the defendant) impermissibly forced a choice between self-representation and the right to testify.

## Decision

- The Fourth Circuit affirmed the convictions.
- The court held the district court’s refusal to permit narrative testimony was a reasonable trial-management restriction aimed at enforcing evidentiary rules and maintaining courtroom order.
- The court held Beckton was not forced to choose between constitutional rights because the district court offered procedures that preserved both self-representation and the ability to testify.
- Because Beckton rejected the available procedures, the court upheld the finding that he chose not to testify.

## Legal Principles

- A defendant’s right to testify is fundamental but subject to reasonable procedural limits to ensure orderly presentation of admissible evidence.
- There is no constitutional right to testify in narrative form; a court may require question-and-answer testimony to manage objections and prevent improper material.
- A defendant’s right of self-representation permits appointment and limited participation of standby counsel, including questioning the defendant as a witness, so long as the defendant retains control of the defense.
- No unconstitutional “forced election” occurs when a court offers reasonable options that protect multiple rights and the defendant refuses to comply with standard procedures.

## Conclusion

The Fourth Circuit upheld Beckton’s convictions, ruling that requiring question-and-answer testimony and permitting limited standby-counsel participation were permissible measures to enforce evidentiary rules and courtroom order and did not deny Beckton either his right to testify or his right to self-representation.


United States v. Beckton, 740 F.3d 303 (4th Cir. 2014)