Convicted murderer Dylann Roof said tearful testimony by family members of those slain in the South Carolina church massacre was excessive and would prejudice jurors who will decide whether he should be sentenced to death.
The 22-year-old white supremacist, found guilty last month of killing nine black people at Charleston's Emanuel African Methodist Episcopal Church in 2015, said in written motions it was unfair for federal prosecutors to pile on given he does not plan to present any mitigating evidence.
Roof is serving as his own lawyer during the penalty phase of his capital trial.
Roof objected to prosecutors' initial plans to call 38 survivors and friends to detail the effects of the murders because that was the same number of witnesses who testified against Oklahoma City bomber Timothy McVeigh after he was convicted of killing 168 people.
"If I don't present any mitigation evidence, the victim-impact evidence will take over the whole sentencing trial and guarantee that I get the death penalty," Roof said in one of several motions decrying prosecutors' tactics.
US District Judge Richard Gergel urged prosecutors to pare down their witness list as jurors heard from victims' loved ones for a second day.
Assistant US Attorney Jay Richardson said prosecutors were making adjustments but noted the large number of victims resulted from Roof's choices.
Prominent capital defence lawyer David Bruck, who represented Roof during the guilt phase of the trial and now serves as his standby counsel, said the defendant's actions proved he was incapable of mounting a proper defense.
"This man cannot protect his own rights," Mr Bruck argued. "He cannot do it."
Judge Gergel refused to let Bruck make objections on Roof's behalf.