Carmel Linot v. United States

Whether the ’look-through’ presumption articulated in Ylst v. Nunnemaker and Harrington v. Richter applies when a federal court of appeals summarily denies, without opinion, a criminal defendant's 'first-time* motion to proceed pro se on direct appeal, where no state or federal court below has had an opportunity to issue a reasoned decision regarding the defendant's constitutional right to self-representation on appeal. (ii)