Filed February 8, 2018
35 To be sure, some courts have held that a request to proceed pro se is timely as long as it comes before the jury is sworn. See, e.g., Fritz v. Spalding, 682 F.2d 782, 784 (9th Cir. 1982); Horton v. Dugger, 895 F.2d 714, 717 (11th Cir. 1990). “The[ir] logic leans upon a Supreme Court holding that in a criminal trial, jeopardy attaches when the jury is sworn.”