See, e.g., Fritz, 682 F.2d at 784 (“[A] motion to proceed pro se is timely if made before the jury is empaneled, unless it is shown to be a tactic to secure delay.”). Although this latter line of cases suggests that “meaningful trial proceedings” do not occur until the jury is sworn, none of these cases actually involved a motion for self-representation that was made after jury selection had begun. Thus, their focus on jury empanelment is made in the abstract and, in our view, is based on an incomplete analysis. In fact, we have only found a single case dealing with a self-representation motion that was made during jury voir dire and that case held that “meaningful trial proceedings” commenced with the beginning of jury selection. See Robards v. Rees, 789 F.2d 379, 382 (6th Cir.1986) (<HOLDING>). The court ruled the motion untimely and
holding that failure to inform the defendant of the constitutionally mandated right to a sixperson jury when one juror became ill after the jury had been sworn but before trial had begun and the defendants attorney waived his rights without consulting defendant mandates a new trial holding that when the purpose of the request is to compare the testimony of jurors but no such comparison was made at the trial level a court need not provide a free voir dire transcript holding that defendants have a right to be present at voir dire holding that even where the case has been called for trial the trial is not deemed to have commenced for speedy trial purposes until the jury is empaneled voir dire has occurred or some other substantial step of trial begins holding a selfrepresentation request untimely where made after voir dire had begun but before the jury had been empaneled