Does a motion for self-representation have to be made before a jury is impaneled?

California, United States of America


The following excerpt is from People v. Rodriguez, A134782 (Cal. App. 2014):

"at least in the absence of extraordinary circumstances, an accused who requests an attorney at the time of a motion for a new trial is entitled to have one appointed, unless the government can show that the request is made for a bad faith purpose." (Id. at p. 701, but see People v. Burton (1989) 48 Cal.3d 843, 853-854 [declining to follow the federal rule that a motion for self-representation is timely if made before the jury is impaneled and must be granted unless made for the purpose of delay].)

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