Can a defendant who elects to represent himself appeal against his conviction?

[54 Cal.App.3d 1063] The notion that 'he has made his bed--now let him lie in it,' has no place in our system of justice. Thus, it appears unrealistic for us to assume that, once he has elected to represent himself, a defendant will not be heard to claim inadequacy of representation as a basis for reversal of his conviction. (See Faretta v. California, supra, 422 U.S. fn. 46, pp. 834--835, 95 S.Ct. 2525.) As appellate judges, we would be seriously remiss in our obligations to our office and justifiably subject to public censure if we blithely affirmed a judgment of conviction where the record before us was replete with prejudicial error, all due to the obvious inability of the accused to properly present his defense. Nor can I agree with a footnote suggestion in the majority's opinion (see Faretta v. California, supra, fn. 46, pp. 834--835, 95 S.Ct. 2525) that the possibility that many criminal defendants representing themselves may use the courtrooms for deliberate disruptions of their trials can be dealt with readily by the trial judge terminating self-representation. Recent experience has dramatically demonstrated that by the time such a sanction is imposed by a trial judge, irreparable damage may have been done.