Moreland apparently swindled people out of $73 million, so I’m going to assume he had a little bit of money, legitimately earned, set aside for his defense. Yet he fought tooth and nail to proceed pro se, which is where all his problems started.
The decision is covered very well, and in some detail, in this post at Decision of the Day, which begins:
In my line of work, I see all kinds of appellate arguments: brilliantly creative, colossally stupid, and everything in between. I enjoy the wacky ones the most, because they tend to inspire spirited opinions, which in turn gives me something interesting to blog about. But occasionally, an appellant makes a wacky argument that really gets under my skin. The Ninth Circuit dealt with three such examples in a decision issued yesterday.
Worthy reading. And it’s worth noting that Moreland was represented on appeal. I have to wonder if his lawyers winced as they filed the brief.