Is a defendant's right to testify in his own defense justified when the trial court rejects a request by the defense to reopen his case?

In sum, courts "must evaluate whether the interests served" by restrictions on a defendant's right to testify "justify the limitation imposed" on this most "'basic'" of rights accruing to a defendant in a criminal case, i.e., the "right to present his own version of events in his own words." (Rock, supra, 483 U.S. at pp. 56, 51, 52.) Here, the trial was relatively short and involved a single defendant, instructions and closing arguments had not been delivered when the request to reopen was made, and the prosecutor had acquiesced to the defense's request to reopen. As for the general interest of the court in conducting the trial in an orderly manner, on the instant facts, any potential for disruption of the proceedings arising from the defense request to reopen was limited. We conclude the restriction on Flores's constitutional right to testify in his own defense was not justified by sufficiently weighty countervailing interests. (People v. Robles (1970) 2 Cal.3d 205, 215 [the right to testify in one's own behalf is of "fundamental importance"]; People v. Vargas (1987) 195 Cal.App.3d 1385, 1394 [the right to testify is a "fundamental" constitutional right "personal to the defendant"].) The trial court's refusal to permit the defense to reopen its case for the limited purpose of eliciting testimony from Flores himself was, therefore, an abuse of discretion. (Rock, supra, 483 U.S. at pp. 55-56

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