California, United States of America
The following excerpt is from People v. Kriss, 158 Cal.Rptr. 420, 96 Cal.App.3d 913 (Cal. App. 1979):
In misdemeanor and, hence, infraction proceedings defendants, if they so desire, may appear solely by counsel pursuant to Penal Code section 977, subdivision (a). 3 However, the court must be certain that the acts of counsel are authorized by the defendant. Mills v. Municipal Court (1973) 10 Cal.3d 288, 110 Cal.Rptr. 329, 515 P.2d 273. In the cases under consideration, as must be true of the overwhelming number of traffic infraction cases, the defendants were unrepresented at any stage of the proceedings.
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