California, United States of America
The following excerpt is from People v. Shah, G044425, Super. Ct. No. 08WF2378 (Cal. App. 2011):
As explained in People v. Burgener (2009) 46 Cal.4th 231, 243-245, the question of whether to apply harmless error analysis to cases involving the mutually exclusive rights of self-representation and appointed counsel is the subject of much debate in our state and federal courts. However, we believe the better course is to
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