Art Fraudster Too Mentally Ill For Pro Se, 9th Circ. Told

Law360, San Francisco (January 10, 2017, 5:01 PM EST) -- Counsel for a San Francisco commercial real estate investor found guilty of defrauding an art dealer told a Ninth Circuit panel at a hearing Tuesday that her client’s 15 findings of contempt during trial should have alerted the judge he wasn’t simply “obnoxious” but also mentally ill and unfit to represent himself.

Luke Brugnara was sentenced to seven years in federal prison for failing to pay New York art dealer Rose Long for the artwork she shipped to him, by artists including Edgar Degas, Willem de...
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