California, United States of America
The following excerpt is from People v. Perez, E073399 (Cal. App. 2020):
First, the trial court could reasonably conclude defendant had some proclivity to vacillate with respect to representation by counsel. Defendant had already discharged his original counsel and opted to represent himself at the time of his preliminary hearing, only to change his mind shortly before his originally scheduled trial date. Further, defendant requested to represent himself during pretrial motions, only to withdraw the request shortly thereafter. Thus, the trial court could reasonably conclude this factor weighed against granting defendant's request. (People v. Jenkins (2000) 22 Cal.4th 900, 962 [The trial court "could reasonably conclude that defendant . . . had some proclivity to
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vacillate with respect to representation by counsel" based solely on one prior request and withdrawal.].)
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