What is the test for a waiver of counsel when a defendant seeks to forgo the right to counsel and engage in self-representation?

California, United States of America


The following excerpt is from People v. Clements, B248854 (Cal. App. 2014):

"No particular form of words, however, is required in admonishing a defendant who seeks to forgo the right to counsel and engage in self-representation. '"The test of a valid waiver of counsel is not whether specific warnings or advisements were given but whether the record as a whole demonstrates that the defendant understood the disadvantages of self-representation, including the risks and complexities of the particular case.'" [Citation.]" (People v. Lawley (2002) 27 Cal.4th 102, 140.) If the trial court's

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