California, United States of America
The following excerpt is from People v. Harbolt, 206 Cal.App.3d 140, 253 Cal.Rptr. 390 (Cal. App. 1988):
People v. Lopez (1977) 71 Cal.App.3d 568, 138 Cal.Rptr. 36, in fact, was the first California case to advance the notion that defendants seeking to represent themselves should be advised of possible penal consequences. 5 It is significant, we believe, that the Lopez court emphasized it was not laying down requirements but only making suggestions as to avenues of inquiry a trial court should make when a defendant seeks to represent himself:
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