The U.S. Supreme Court weakened a criminal defendant’s ability to choose his own counsel in February, when it limited defendants’ ability to challenge a pretrial freeze of their assets.

In Kaley v. United States, the U.S. Supreme Court affirmed the U.S. Court of Appeals for the Eleventh Circuit’s holding that a criminal defendant is not constitutionally entitled to a pretrial hearing to challenge the factual foundation supporting a grand jury’s probable cause determination to retrieve seized assets.