California, United States of America
The following excerpt is from People v. Cervantes, 150 Cal.Rptr. 819, 87 Cal.App.3d 281 (Cal. App. 1978):
However, we also conclude that some standard of review short of an automatic reversal should be applied in order to inject more fairness into a defendant's game of "waive the lawyer." The effect of a reversal per se rule under circumstances where defendant may otherwise have a lost cause is not compatible with maintaining an efficient and economical system of system. As previously noted, "(r)etrials are time-consuming, expensive, traumatic to the personnel involved and a matter of considerable concern to the public." (People v. Lopez, supra, 71 Cal.App.3d 568, 572, 138 Cal.Rptr. 36, 38.) Accordingly, we hold that the standard to be applied here is the "harmless beyond a reasonable doubt" error test of Chapman v. California, supra,386 U.S. 18, 87 S.Ct. 824, 17 L.Ed.2d 705.
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