Can a criminal defendant who represents himself at trial be denied a right to consult the court on behalf of their own counsel?

Criminal defendants who represent themselves at trial have no constitutional right to advisory counsel. In fact, this is one of the warnings that must be given a defendant considering self-representation. (See People v. Weber (2013) 217 Cal.App.4th 1041, 1057-1058 [defendants seeking to represent themselves should be warned, among other things, that they have no right to advisory counsel]; People v. Phillips (2006) 135 Cal.App.4th 422, 428 [same].)

Although defendants have no right to advisory counsel, trial courts have authority to appoint advisory counsel to a self-represented criminal defendant. (People v. Bigelow (1984) 37 Cal.3d 731, 742.) In Bigelow, the court found it was an abuse of discretion to deny advisory counsel given the defendant's limited education, foreign nationality, unfamiliarity with California law, and the complexities of defending a capital case. (Id. at pp. 743-744.)