Fourth Circuit holds that a knowing waiver to jury trial is not dependent upon a good attorney-client relationship

In United States v. Boynes, Boynes argued that he "could not have" knowingly, intelligently and voluntarily waived his right to a jury trial because his relationship with his attorney was "characterized by adversarial contentious interactions." The Fourth Circuit rejected this argument.

A knowing, intelligent, and voluntary waiver and contentiousattorney-client interactions are not mutually exclusive. Although there are no doubt circumstances calling into question the validity of a jury waiver that would require reversal if not sufficiently resolved by the district court, that is certainly not the case here. On this record we are presented with a presumptively valid written waiver, a full hearing on the validity of the waiver in open court, and a judicial finding that the waiver is knowing, intelligent, and voluntary. The district court noted there is "no evidence" that Everhart filed the motion to waive jury trial without Boynes’ consent.