What is the test for being pro per?

California, United States of America


The following excerpt is from People v. Lavin, B266599 (Cal. App. 2016):

"The Court: You were not pro per. In People v. Sattiewhite, S-A-T-T-I-E-W-H-I-T-E, at 59 Cal.4th 466, it held that counsel's assertion of -

"The Defendant: She just spit on me, your honor. She just spit on me.

"The Court: I don't believe that, sir.

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