When a defendant's request to represent himself was granted, when the trial court appointed a defense investigator, legal runner, and standby counsel, as well as granting pro. per. funds and telephone access, is he entitled to reversal?

California, United States of America


The following excerpt is from People v. Allen, B275519 (Cal. App. 2017):

When defendant's request to represent himself was granted, the trial court appointed a defense investigator, a legal runner, and standby counsel; as well as granting pro. per. funds and telephone access. Under such circumstances, defendant was not denied all means to prepare his defense; thus, he is not entitled to reversal without showing error and resulting prejudice. (People v. James (2011) 202 Cal.App.4th 323, 335.) Defendant has not demonstrated error, and makes no prejudice argument.

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