United States of America v. Jeffrey Alan Bosaw

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted June 25, 2024
Decided July 2, 2024
Before
CANDACE JACKSON-AKIWUMI, Circuit Judge
JOHN Z. LEE, Circuit Judge
DORIS L. PRYOR, Circuit Judge
No. 23-3416
UNITED STATES OF AMERICA,
Plaintiff-Appellee,
v.
JEFFREY ALAN BOSAW,
Defendant-Appellant.
Appeal from the United States District
Court for the Central District of Illinois.
No. 20-cr-40070-001
Sara Darrow,
Chief Judge.
O R D E R
Jeffrey Bosaw was convicted of attempted enticement of a minor. 18 U.S.C.
§ 2422(b). He filed a notice of appeal, but his appointed counsel asserts that the appeal
is frivolous and moves to withdraw. See Anders v. California, 386 U.S. 738, 744 (1967).
In her Anders brief, counsel does not address two hearings that preceded the
trial—a hearing on Bosaw’s competency to stand trial and a hearing on his waiver of his
right to counsel. Both matters are vital to the fairness of criminal proceedings, see United
States v. Nichols, 77 F.4th 490, 498–500 (7th Cir. 2023), and a complete Anders brief must
review “anything in the record that might arguably support the appeal.” Anders, 386
U.S. at 744. (emphasis added).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with FED. R. A PP. P. 32.1

-- 1 of 2 --

No. 23-3416 Page 2
IT IS ORDERED that counsel shall file a supplement to the Anders motion by
July 18, 2024, addressing whether the district court properly determined that Bosaw (1)
was competent to stand trial and (2) voluntarily and knowingly waived his right to
counsel.

-- 2 of 2 --