The trial court in this case did not engage in the proper analysis and a remand was necessary to address these various factors.United States v. Ruston, 565 F.3d 892 (5th Cir. 2009)The trial court erred in failing to sua sponte conducting a competency hearing when the defendant, acting pro se, cross-examined witnesses about completely irrelevant matters and accused the judge and agents of being members of a conspiracy.Hummel v. Rosemeyer, 564 F.3d 290 (3rd Cir. 2009)The defendant was tried for murder in state court and found guilty.