California, United States of America
The following excerpt is from King v. Superior Court, 107 Cal.App.4th 929, 132 Cal.Rptr.2d 585 (Cal. App. 2003):
In order to permit meaningful appellate review of forfeiture of counsel, a trial court must set forth on the record its factual findings that support a forfeiture of the right to counsel. (Cf. People v. Superior Court (Romero) (1996) 13 Cal.4th 497, 531, 53 Cal.Rptr.2d 789, 917 P.2d 628 [requiring reasons for dismissal of strike prior be set forth in a minute order].) When a defendant waives his right to counsel, we require an unequivocal request for self-representation. (People v. Marshall (1997) 15
[107 Cal.App.4th 949]
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