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NOTES
[1] Statutory citations are to Title 21 of the United States Code, unless otherwise noted.
[2] The Court in Sarff held that a defendant had not been deprived of counsel where, following the trial judge's warning to remain silent, he had only continued to respond to the court.
[3] Nor is the fact that the defendant did not testify at trial relevant. In Ex parte Crymes, 630 So.2d 125, 129 (Ala.1993), the Alabama Supreme Court held that the defendant's failure to testify at his capital murder trial was unconstitutional, despite the fact that the defendant had testified at his co-defendant's trial. That court said, "Although Crymes may have been unavailable in the constitutional sense, he had a statutory right to do more than he did." Id.
[4
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