What is the test for a defendant to represent herself in a civil trial?

MultiRegion, United States of America

The following excerpt is from United States v. DiMartino, 949 F.3d 67 (2nd Cir. 2020):

against her. Clark v. Perez, 510 F.3d 382, 386-88 (2d Cir. 2008). Despite "ample notice" that the defendant would mount a "disruptive, political defense" at trial, the trial court determined that she was competent to proceed to trial and represent herself pro sea determination that was never challenged. Id.

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