Rule 12(c)(3) Good-Cause Requirement Bars Untimely Suppression Challenges on Direct Appeal (Anders Disposition)
Introduction
In United States v. Cooks (10th Cir. Mar. 5, 2026) (unpublished “Order and Judgment”),
the Tenth Circuit dismissed Donald Eugene Cooks’s direct criminal appeal after appointed counsel filed an
Anders brief and moved to withdraw. The case arose from a suspected mail-theft scheme centered on an
Oklahoma City post office, a Motel 6 room used to store packages, and later alleged witness tampering.
The appeal’s central potential issue was whether evidence should have been suppressed due to an officer’s
warrantless entry into Cooks’s motel room—an issue that trial counsel raised only mid-trial, after the
pretrial motion deadline.
The key appellate questions were procedural rather than merits-based: (1) whether the district court erred
in rejecting the late suppression attempt under Federal Rule of Criminal Procedure 12; (2) whether an
ineffective-assistance claim could be reached on direct appeal; and (3) whether any other arguable issues
existed, including the validity of Cooks’s post-trial waiver of counsel at sentencing.
Summary of the Opinion
Applying the independent review required by Anders v. California, the panel found no non-frivolous
grounds for appeal. It held that the suppression issue was not preserved because trial counsel failed to file
a timely pretrial motion to suppress and did not show “good cause” for the delay as required by
Rule 12(c)(3). The court declined to entertain an ineffective-assistance claim on direct appeal because the
claim was not raised and ruled upon below and the record was insufficient. It also found no colorable
challenges to the indictment, jury instructions, sufficiency of the evidence, sentence reasonableness, or the
district court’s Faretta colloquy allowing self-representation at sentencing. The court therefore granted
counsel’s motion to withdraw and dismissed the appeal.
Analysis
Precedents Cited
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Anders v. California, 386 U.S. 738, 744 (1967)
Anders supplies the procedural framework for counsel’s withdrawal in a direct criminal appeal when
counsel concludes the appeal is frivolous. The opinion closely tracks Anders: counsel must identify
anything that might arguably support an appeal; the defendant may respond; and the court must conduct
an independent review. Here, the Tenth Circuit emphasized that it performed that independent review and,
finding no “arguable ground,” dismissed the appeal.
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Faretta v. California, 422 U.S. 806, 835 (1975)
Faretta governs a defendant’s constitutional right to self-representation if the waiver of counsel is
knowing and voluntary. The panel relied on the district court’s Faretta hearing to reject any arguable
claim that Cooks’s waiver of counsel for sentencing was invalid.
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United States v. Dunbar, 718 F.3d 1268, 1278 (10th Cir. 2013)
The court cited Dunbar for the rule that a represented defendant has no right to “hybrid representation”
(i.e., filing pro se motions while represented by counsel). This mattered because Cooks had filed a pro se
motion to suppress months before trial, but the district court denied it on that basis. The panel deemed
that denial unarguable on appeal, foreclosing any attempt to treat the earlier pro se motion as preservation.
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United States v. Galloway, 56 F.3d 1239, 1240 (10th Cir.1995) (en banc)
Galloway provides the Tenth Circuit’s strong presumption that ineffective-assistance claims should be
raised in collateral proceedings under 28 U.S.C. § 2255, not on direct appeal. The panel used Galloway
to characterize Cooks’s ineffective-assistance argument as “presumptively dismissible.”
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United States v. Flood, 635 F.3d 1255, 1260 (10th Cir. 2011)
Flood sets a narrow exception: ineffective-assistance may be considered on direct appeal only where
the issue was raised and ruled upon by the district court and a sufficient factual record exists. The panel
found neither condition satisfied, so Flood foreclosed direct review of counsel’s alleged failure to file a
timely suppression motion.
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United States v. Pemberton, 94 F.4th 1130, 1143 (10th Cir.)
Pemberton was cited for the Tenth Circuit’s articulation of “four requirements” to grant a request to
waive counsel and for the proposition that a “contemporaneous and comprehensive Faretta hearing” is
generally sufficient to ensure a knowing waiver. The panel used Pemberton to conclude that the record
would not support a challenge to the self-representation decision at sentencing.
Legal Reasoning
1) The suppression issue failed on timeliness and “good cause,” not on Fourth Amendment merits
The opinion treats the Fourth Amendment question (warrantless entry into a motel room) as potentially
significant—defense counsel even conceded it “appears to involve a straightforward Fourth Amendment
violation.” But the court did not reach the merits because the procedural default was dispositive.
Under Fed. R. Crim. P. 12(b)(3)(C), suppression motions must be made before trial if the basis is
reasonably available and resolvable without a trial on the merits. Under Fed. R. Crim. P. 12(c)(3),
missing the deadline makes the motion untimely, and the court may consider it only if the party shows
good cause.
The district court asked whether counsel knew the factual basis before the deadline, and counsel admitted he
did. With that admission and no articulated reason for delay, the panel found “no colorable argument” that
the district court erred in denying the late suppression attempt. In other words, the appeal failed because
Rule 12(c)(3) makes “good cause” a mandatory gateway, and the record contained no basis to satisfy it.
2) The earlier pro se motion to suppress could not preserve the issue
Cooks’s prior pro se suppression motion did not help him on appeal because, while represented, he had no
right to file it independently. By invoking United States v. Dunbar, the panel treated the district court’s
refusal to entertain the pro se motion as unassailable under established anti-hybrid-representation doctrine.
This matters in practice: defendants cannot “backstop” counsel’s omissions by filing pro se motions when
counsel remains of record.
3) Ineffective assistance was routed to collateral review
Cooks attempted to reframe counsel’s missed Rule 12 deadline as ineffective assistance. The panel applied
the usual Tenth Circuit pathway: such claims almost always belong in a § 2255 proceeding, where a fuller
record can be developed (e.g., counsel’s reasons, strategy, investigation, and client communications).
Under United States v. Flood, the Tenth Circuit will consider ineffective-assistance claims on direct appeal
only if the issue was raised and ruled upon below and the record is adequate. Because neither was true, the
court concluded the claim was not arguable in this direct appeal.
4) No other arguable issues, including sentencing and waiver of counsel
The panel agreed with counsel’s assessment that other typical appellate targets—indictment defects, jury
instruction errors, sufficiency challenges, and procedural/substantive reasonableness of the sentence—did
not present non-frivolous arguments on this record.
It also addressed (briefly but pointedly) the post-trial waiver of counsel, relying on the district court’s
Faretta hearing and the framework described in United States v. Pemberton to conclude there was no
arguable basis to claim the waiver was unknowing or involuntary.
Impact
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Rule 12 enforcement is outcome-determinative: Even where a potential Fourth Amendment problem
looks substantial, failing to file a timely suppression motion—and failing to demonstrate “good cause”—
can prevent any merits review.
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Limits of pro se “insurance filings”: The reaffirmation of anti-hybrid-representation principles
underscores that represented defendants generally cannot preserve issues by filing pro se motions.
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Channeling IAC claims to § 2255: The decision exemplifies the Tenth Circuit’s continued insistence
that ineffective-assistance claims ordinarily be litigated collaterally, where an evidentiary record can be
developed.
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Practical significance in Anders cases: The opinion shows how procedural defaults and record
constraints often drive the “no arguable issues” conclusion in Anders dispositions.
Because the order is expressly “not binding precedent” (except under law-of-the-case, res judicata, and
collateral estoppel), its formal precedential impact is limited; nonetheless, its reasoning is a clear, usable
illustration of how the Tenth Circuit applies Rule 12(c)(3) and its direct-appeal ineffective-assistance doctrine.
Complex Concepts Simplified
- Anders brief
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A filing by appointed appellate counsel stating that, after careful review, counsel cannot find a non-frivolous
appellate issue—paired with a motion to withdraw. The court must independently review the record before
allowing withdrawal and dismissing/affirming.
- Motion to suppress
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A request to exclude evidence obtained in violation of the Constitution (commonly the Fourth Amendment).
If granted, the jury typically will not see or hear that evidence.
- Rule 12(b)(3)(C) / Rule 12(c)(3)
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These rules impose a deadline: suppression issues must be raised before trial when feasible. If missed, the
defendant must show “good cause” for the late filing; otherwise the court can deny the motion as untimely
without deciding whether the search was unlawful.
- Hybrid representation
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Trying to proceed both with a lawyer and pro se at the same time. Federal courts generally do not allow a
represented defendant to file motions independently.
- Faretta hearing
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A colloquy where the judge ensures the defendant understands the risks of self-representation and is
knowingly and voluntarily waiving the right to counsel.
- Ineffective assistance of counsel (IAC)
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A claim that counsel’s performance was constitutionally deficient and prejudicial. Appellate courts often
require such claims to be brought in a later § 2255 proceeding so facts outside the trial record can be developed.
Conclusion
United States v. Cooks reinforces a procedural lesson with substantive consequences: suppression arguments
must be timely under Rule 12, and without a showing of “good cause” under Rule 12(c)(3), even potentially
strong Fourth Amendment issues may never be reached on the merits. The decision also follows entrenched
Tenth Circuit doctrine that ineffective-assistance claims belong in § 2255 proceedings absent a developed
record and a ruling below, and it confirms that a comprehensive Faretta hearing will generally defeat
appellate challenges to self-representation. In the broader criminal appellate landscape, the opinion exemplifies
how procedural preservation and record development often determine whether any “arguable issue” exists—especially
in Anders cases.