What is the test for a motion to revoke in propria persona status and have an attorney appointed?

California, United States of America


The following excerpt is from People v. Esqueda, H042285 (Cal. App. 2018):

"A request to revoke in propria persona status and have an attorney appointed is committed to the sound discretion of the trial court. [Citation.] However, such a request must be unequivocal, just as a request to waive counsel must be unequivocal. [Citation.]" (People v. Weber (2013) 217 Cal.App.4th 1041, 1061.) An abuse of discretion in this regard is reviewed for harmless error. (People v. Ngaue (1991) 229 Cal.App.3d 1115, 1127.)5

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