California, United States of America
The following excerpt is from Ligda v. Superior Court, 5 Cal.App.3d 811, 85 Cal.Rptr. 744 (Cal. App. 1970):
'We commend the action of the district judge, for while the appellants had a clear right to represent themselves, unless some unusual circumstances appeared, i.e., incompetence, coerced waiver, the assistance of counsel was ever present throughout the trial and during the post-conviction hearings. See Hollander v. State, 82 Nev. 345, 418 P.2d 802.'
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