If a defendant waives his right to counsel after being advised of the filing of a criminal complaint, is that waiver valid?

California, United States of America


The following excerpt is from People v. Ferguson, A133113 (Cal. App. 2013):

If a defendant has previously waived his right to counsel after being brought before a magistrate and advised of the filing of a criminal complaint, the trial court is required by Penal Code section 987 to readvise the defendant of his right to counsel when the defendant is arraigned in superior court on the information and to secure another waiver of the defendant's right to counsel. (People v. Crayton (2002) 28 Cal.4th 346, 360-361.)

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