Does a defendant's request to represent himself at a jury trial need to be considered to have been considered prior to trial?

California, United States of America


The following excerpt is from People v. Ellis, B243116 (Cal. App. 2013):

People v. Tyner, supra, 76 Cal.App.3d 352 is distinguishable. In that case, the defendant's request to represent himself was made on the day the matter was called for jury trial and was viewed as having been made prior to trial. Here, defendant did not

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