What is the test for a judge to order that a defendant be represented by counsel at trial?

The court properly exercised its discretion here. Asmerom was argumentative, insulting and disrespectful to the court, and either unable or unwilling to control his outbursts and abide by courtroom rules and protocol despite multiple warnings that failure to do so would result in the termination of his right to represent himself. " '[T]rial judges confronted with disruptive, contumacious, stubbornly defiant defendants must be given sufficient discretion to meet the circumstances of each case.' . . . [W]hen a defendant's obstreperous behavior is so disruptive that the trial cannot move forward, it is within the trial judge's discretion to require the defendant to be represented by counsel." (United States v. Brock (7th Cir. 1998) 159 F.3d 1077, 1079.) This is such a case.

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