What is the test for a motion to proceed pro se?

California, United States of America


The following excerpt is from People v. Brown, A151961 (Cal. App. 2019):

p. 20, italics added.) "[W]hen a motion to proceed pro se is timely interposed, a trial court must permit a defendant to represent himself upon ascertaining that he has voluntarily and intelligently elected to do so, irrespective of how unwise such a choice might appear to be." (People v. Windham (1977) 19 Cal.3d 121, 128, italics omitted.)

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