California, United States of America
The following excerpt is from People v. Castille, 133 Cal.Rptr.2d 489 (Cal. App. 2003):
Shields' closing argument was not irrational. Despite its shortcomings, the argument was not bizarre or nonsensical in its content. Just as in People v. Koontz, supra, 27 Cal.4th at page 1065, any deficiencies in Shields' self-representation "suggest not incompetency to stand trial but, rather, the lack of legal training common to most pro se defendants."
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