California, United States of America
The following excerpt is from People v. Rich, B253180 (Cal. App. 2015):
We take our direction from People v. Welch. The trial court's decision " 'will not be disturbed in the absence of a strong showing of clear abuse.' [Citation.]" (People v. Welch, supra, 20 Cal.4th at p. 735 ["a trial court must undertake the task of deciding whether a defendant is and will remain so disruptive, obstreperous, disobedient, disrespectful or obstructionist in his or her actions or words as to preclude the exercise of the right to self-representation"; the reviewing court applies "the same deference [as it does to a decision to terminate the defendant's right to self-representation] when it comes to deciding whether a defendant's motion for self-representation should be granted in the first instance"].)
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