California, United States of America
The following excerpt is from People v. Carroll, 140 Cal.App.3d 135, 189 Cal.Rptr. 327 (Cal. App. 1983):
It has been held that a defendant may waive his constitutional right to confront witnesses by disruptive conduct in the courtroom. (See Illinois v. Allen, supra, 397 U.S. 337, 90 S.Ct. 1057, 25 L.Ed.2d 353; People v. Booker (1977) 69 Cal.App.3d 654, 138 Cal.Rptr. 347.) However, these cases have involved defendants who exhibited violently disruptive conduct and who continued to have defense counsel present while they were excluded from the courtroom.
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