Can a defendant who is represented by counsel during the first part of a criminal trial invoke his right to self-representation mid-trial?

People v. Windham, supra, 19 Cal.3d 121, 137 Cal.Rptr. 8, 560 P.2d 1187 (Windham), on which the trial court relied, addressed the situation in which a defendant who is represented by counsel during the first part of a trial invokes his or her right to self-representation midtrial. We held that in order to invoke the constitutionally mandated right of self-representation, a defendant in a criminal trial must unequivocally assert that right within a reasonable time prior to the commencement of the trial. Once a defendant has chosen to proceed to trial represented by counsel, his or her demand to discharge counsel and assume the defense shall be addressed to the sound discretion of the court. (Id. at pp. 127-128,137 Cal.Rptr. 8, 560 P.2d 1187.) Factors for the trial court to consider in assessing such a request made after the commencement of the trial include "the quality of counsel's representation of the defendant, the defendant's prior proclivity to substitute counsel, the reasons for the request, the length and stage of the proceedings, and the disruption or delay [that] might reasonably be expected to follow the granting of such a motion." (Id. at p. 128, 137 Cal.Rptr. 8, 560 P.2d 1187.)

Defendant's case presents the reverse scenario, i.e., a self-represented defendant who, after commencement of the trial, seeks to relinquish responsibility for his own defense and obtain the appointment of counsel to represent him for the remainder of the trial. In this situation, we have indicated that the Windham factors apply and that the trial court must consider the totality of the circumstances in exercising its discretion. (People v. Gallego (1990) 52 Cal.3d 115, 164, 276 Cal.Rptr. 679, 802 P.2d 169.)