On October 15, Attorney Wood filed an amicus brief in the Supreme Judicial Court on behalf of the Cato Institute in Commonwealth v. Francis. In this case, trial counsel volunteered to serve as Mr. Francis's pro bono counsel without telling Mr. Francis that he was not being paid because the trial judge refused to appoint trial counsel as not qualified to handle murder cases. We argue that depriving Mr. Francis of this crucial information was a violation the right to choice of counsel and resulted in structural error requiring automatic reversal.