Background
Stephen Snyder, a prominent Maryland medical malpractice attorney for nearly fifty years, devised an extortion scheme targeting the University of Maryland Medical System’s transplant center. Beginning in 2017, after representing patients with transplant-related claims, Snyder threatened the hospital’s officials with a targeted advertising campaign, media blitz, and negative publicity unless they paid him $25 million personally as a “consultant.” At a private dinner in 2018, Snyder showed gruesome post-operative photos to the hospital’s chief medical officer and repeatedly threatened to “take down” the hospital if officials did not “cooperate.” Over subsequent months, he escalated demands, warning that the hospital would be destroyed and executives fired if they refused. A grand jury indicted Snyder in October 2020 on charges of attempted extortion under the Hobbs Act and Travel Act violations.
Snyder retained counsel initially but his attorney withdrew. Snyder then insisted on representing himself. The magistrate judge conducted two Faretta hearings—one in December 2023 and another in October 2024, just before trial. Between these hearings, Snyder’s health visibly declined: he disclosed he was under 24-hour medical care, being treated by multiple neurologists and specialists, had failed a short-term memory test, had gait problems, and was being investigated for possible Parkinson’s disease. Nevertheless, Snyder consistently and firmly refused to accept appointed counsel, insisting he was “prepared” with opening statements and cross-examinations ready.
At the November 2024 trial, Snyder’s performance deteriorated markedly. He repeatedly asked irrelevant questions, violated pretrial orders by mentioning a barred prosecutor, mocked witnesses in ways the court found “completely out of line, rude, and shocking,” and spoke to the judge in a “heated” and “threatening” tone. The judge found him in contempt and remanded him to U.S. Marshals custody overnight. The jury convicted Snyder on all eight counts. He appealed, arguing the court erred in allowing him to proceed pro se despite his cognitive impairment and poor trial performance.
The Court’s Holding
The Fourth Circuit affirmed the conviction, holding that a defendant who is competent to stand trial is necessarily competent to waive the right to counsel, even if that defendant’s trial performance suffers due to cognitive decline or age-related health issues. Snyder’s appellate counsel conceded at oral argument that Snyder was competent to stand trial at every stage of the proceedings, which the court found fatal to his appeal. The magistrate judge had conducted thorough Faretta hearings in which Snyder demonstrated understanding of the charges, possible penalties, applicable law, and disadvantages of self-representation. He repeatedly and emphatically rejected suggestions that he accept counsel, insisting he was prepared.
The court rejected Snyder’s argument that the district court should have sua sponte revoked his self-representation rights under Indiana v. Edwards, 554 U.S. 164 (2008). While Edwards permits courts to deny self-representation rights if a defendant lacks mental capacity to conduct trial defense, it does not require courts to do so. The Fourth Circuit emphasized that courts are not obligated to protect defendants from their own voluntary choices, even poor ones. The court noted that virtually every pro se defendant performs worse than trained attorneys, and yet courts regularly allow them to self-represent. Snyder, as a trained attorney with decades of experience, actually performed better than most pro se defendants despite his poor courtroom demeanor. The court cautioned that imposing a requirement to revoke self-representation rights would “open the floodgates” to pro se defendants challenging convictions after poor performance, contradicting the Supreme Court’s principle in Faretta that defendants cannot complain their own advocacy was inadequate.
On secondary issues, the court affirmed the trial court’s refusal to give a reliance-on-counsel jury instruction because Snyder failed to establish that he had fully disclosed all pertinent facts to his ethics attorney. The attorney testified he knew little about the consultancy arrangement and never advised Snyder that threatening the hospital was ethical. The court also upheld the limitation on a witness’s testimony to respect her nondisclosure agreement and rejected Snyder’s request for jury voir dire about news coverage of his contempt confinement.
Key Takeaways
- Mental competence to stand trial necessarily includes competence to waive counsel; courts need not impose a higher standard for self-representation even when cognitive decline is evident.
- Indiana v. Edwards permits but does not require courts to revoke a defendant’s self-representation rights; poor trial performance alone cannot justify revocation absent inability to consult counsel or lack of rational understanding.
- The reliance-on-counsel defense requires proof of both full disclosure of pertinent facts to an attorney and good-faith reliance on that attorney’s advice; partial or incomplete disclosure defeats the instruction.
- Courts retain broad discretion in trial management, including limiting witness testimony to enforce valid agreements and controlling examination scope without requiring jury voir dire about collateral matters.
Why It Matters
This decision significantly constrains pro se defendants’ appellate remedies for poor self-representation, establishing a bright-line rule that competence to stand trial forecloses later challenges based on cognitive decline or courtroom incompetence. While courts retain discretionary power under Edwards to appoint counsel despite a defendant’s wishes, the Fourth Circuit’s holding that such power is not mandatory creates a high bar for defendants seeking reversal on these grounds. For trial judges, the decision provides substantial protection from reversal even when allowing self-representation seems imprudent, reducing pressure to intervene in a defendant’s voluntary choice to proceed pro se. The ruling also reflects judicial skepticism toward permitting defendants a “second bite at the apple” by attacking their own trial performance post-conviction.
For prosecutors and defendants alike, the opinion clarifies that the reliance-on-counsel defense is narrowly tailored: attorneys consulted must have clear, complete knowledge of the defendant’s actual conduct and must explicitly authorize it. The decision thus limits defendants’ ability to shield illegal conduct by asserting they consulted counsel, requiring that counsel have full knowledge of the scheme before the defense becomes viable. The case reinforces Faretta’s core holding that defendants’ Sixth Amendment right to self-representation, while robust, carries consequences they cannot escape by later claiming incompetence or poor judgment.