How have courts treated a defendant's request for self-representation?

For example, the court cited one case, where the trial court responded to the defendant's request by asking whether he was certain he wanted to represent himself. The defendant said he was. "The reviewing court nonetheless found the record as a whole did not reflect an unequivocal request, but rather a spur of the moment decision prompted by the denial of defendant's motion for substitute counsel. [Citation.]" (People v. Marshall, supra, 15 Cal.4th at p. 21.) In another case, "the defendant stated: ' "I want to fight it in pro per then. Relieve him and I do this myself." ' The reviewing court considered the record as a whole, including the defendant's failure to assert the right of self-representation at a later hearing, and independently determined that the defendant's request for self-representation was an impulsive response to the trial court's denial of his request for substitute counsel. Examining the question whether the defendant in fact wanted to represent himself, the court stated: '[The defendant's] emotional response when disappointed by the trial court's

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