California, United States of America
The following excerpt is from People v. Susan Mae Polk, 10 Cal. Daily Op. Serv. 15, 449, 118 Cal.Rptr.3d 876, 190 Cal.App.4th 1183 (Cal. App. 2010):
Defendant contends that, if she has forfeited her right to raise the inadequacy of the Miranda warnings because the issue was not presented to the trial court, the failure to raise the issue was a consequence of ineffective assistance of counsel. Defendant, however, represented herself in the trial resulting in the judgment presently on appeal. "Defendants who have elected self-representation may not thereafter seek reversal of their convictions on the ground that their own efforts were inadequate and amounted to a denial of effective assistance of counsel." ( People v. Bloom (1989) 48 Cal.3d 1194, 1226, 259 Cal.Rptr. 669, 774 P.2d 698.)
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