Does the trial court have any discretion in denying a defendant's request to represent himself?

California, United States of America


The following excerpt is from People v. Luzano, B253623 (Cal. App. 2015):

The trial court also did not abuse its discretion in denying defendant's request to represent himself. Even apart from defendant's intentional efforts to prevent the court from providing him the necessary advisements by cussing out the trial court on one occasion and absenting himself on another, this very same disruptive conduct provides a sufficient basis for denying his request for self-representation. (People v. Kirvin (2014) 231 Cal.App.4th 1507, 1515 ["A defendant's in-court misconduct can warrant the denial or revocation of a defendant's right to represent himself."].)

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