California, United States of America
The following excerpt is from People v. Clark, 10 Cal.Rptr.2d 554, 3 Cal.4th 41, 833 P.2d 561 (Cal. 1992):
The gist of defendant's motions on October 5 and October 12 was that he wished to represent himself, not to substitute counsel. "A request for self-representation does not trigger a duty to conduct a Marsden inquiry (supra, 2 Cal.3d 118 [84 Cal.Rptr. 156, 465 P.2d 44] ) or to suggest substitution of counsel as an alternative." (People v. Crandell, supra, 46 Cal.3d 833, 854-855, 251 Cal.Rptr. 227, 760 P.2d 423.) The court did not commit Marsden error in failing to conduct a hearing on those dates into the reasons for defendant's dissatisfaction with counsel.
(ii) Defendant's Mental Competence to Waive Counsel
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