California, United States of America
The following excerpt is from People v. Avina, E070428 (Cal. App. 2020):
"A defendant's request to proceed pro per must be unequivocal, voluntary, and intelligent. Often, defendants make a self-representation motion in the heat of the moment, after a different motion has been denied." (People v. Becerra (2016) 63 Cal.4th 511, 519.) "'[A] [Faretta] motion made out of a temporary whim, or out of annoyance or
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frustration, is not unequivocal even if the defendant has said he or she seeks self-representation.' [Citation.]" (People v. Stanley (2006) 39 Cal.4th 913, 932.)
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