California, United States of America
The following excerpt is from People v. Scott, 64 Cal.App.4th 550, 75 Cal.Rptr.2d 315 (Cal. App. 1998):
Conspicuously absent from California Constitution, article I, section 15, is the language in article I, former section 13 which gave the party accused the right " 'in any court whatever, ... to appear and defend, in person and with counsel.' " (People v. Ashley, supra, 59 Cal.2d at p. 360, fn. 6, 29 Cal.Rptr. 16, 379 P.2d 496, italics added.) Thus, that crucial language is no longer extant. 11
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b. The post-Faretta decision of In re Walker.
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