What is the test for terminating a parent's right to self-representation in a juvenile dependency proceeding?

The right to self-representation may be terminated where a litigant is unable to abide by the rules of procedure and courtroom protocol. (People v. Rudd (1998) 63 Cal.App.4th 620, 632.) Here, the review hearing was already long past due and father was still unable to secure the presence of his witnesses. It was not error for the juvenile court to terminate his pro per status under these circumstances.

We also reject father's argument the juvenile court should have opted to force him to proceed without witnesses rather than reappoint counsel. "Because a parent's right to self-representation in a juvenile dependency proceeding is statutory, rather than constitutional, our review of the assertion of the right to self-representation is evaluated under the harmless error standard of People v. Watson (1956) 46 Cal.2d 818, 836. [Citation]." (In re A.M., supra, 164 Cal.App.4th at p. 928.) Father makes no attempt to show, and it is doubtful he could, that he would have fared better with no counsel and no witnesses, compared to the reappointment of counsel.