Can a defendant's untimely request to represent himself be denied at the time of sentencing?
California, United States of America
The following excerpt is from People v. Hayden, C074993 (Cal. App. 2014):
We find no abuse of discretion in the trial court's denial of defendant's untimely request to represent himself. (See People v. Doolin (2009) 45 Cal.4th 390, 454-455 [a defendant's motion to represent himself that came at the time of sentencing was "manifestly untimely"; People v. Ruiz (1983) 142 Cal.App.3d, 780, 792 [an untimely self-representation request is committed to the trial court's sound discretion].)
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