Erickson v. Medina

How later courts describe this case

• holding that after defendant has waived counsel, a subsequent request for counsel prior to sentencing requires the court to inquire whether the waiver has been revoked
• concluding that “exceeding” language in articles was a limitation upon duration of the voyage
• court under no obligation to inquire anew at each phase of case whether right to counsel was waived unless “something transpired in the interim which justified such further inquiry, such as a request by [the defendant] for counsel and advise when he appeared for sentencing”