Can a criminal defendant proceed pro se?
The following excerpt is from People v. Ryan, 605 N.Y.S.2d 235, 626 N.E.2d 51, 82 N.Y.2d 497 (N.Y. 1993):
A criminal defendant may be permitted to proceed pro se if the request is timely and unequivocal, there has been a knowing and intelligent waiver of the right to counsel, and defendant has not engaged in conduct that would interfere with a fair and orderly trial (People v. McIntyre, 36 N.Y.2d 10, 17, 364 N.Y.S.2d 837, 324 N.E.2d 322). Although the trial court in the present case perceived defendant's legal skills to be wanting, and therefore denied the motion for defendant's "own protection," that was not a proper ground for decision. What we said in People v. Davis (49 N.Y.2d 114, 120, 424 N.Y.S.2d 372, 400 N.E.2d 313) applies equally here:
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