California, United States of America
The following excerpt is from People v. Ortega, B278160 (Cal. App. 2017):
appear in propria persona an empty formality." (Id. at p. 653.) Thus, when an untimely motion for self-representation is made too close to trial or during trial, the trial court may deny it, but if the court chooses to grant it, a refusal to give the defendant reasonable time, if necessary to prepare a defense, can be an abuse of discretion and a denial of due process. (People v. Jenkins (2000) 22 Cal.4th 900, 1039-1040 (Jenkins).)
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