What is the test for denying a defendant's right to self-representation?

If the defendant unequivocally asks to represent himself, a court may deny such request when his "conduct . . . gives the trial court a reasonable basis for believing that his self-representation will create disruption." (People v. Welch (1999) 20 Cal.4th 701, 734 (Welch).) "This rule is obviously critical to the viable functioning of the courtroom. A constantly disruptive defendant who represents himself, and who therefore cannot be removed from the trial proceedings as a sanction against disruption, would have the capacity to bring his trial to a standstill." (Ibid.) "[A] trial court must undertake the task of deciding whether a defendant is and will remain so disruptive, obstreperous, disobedient, disrespectful or obstructionist in his or her actions or words as to preclude the exercise of the right to self-representation. The trial court possesses much discretion when it comes to terminating a defendant's right to self-representation and the exercise of that discretion 'will not be disturbed in the absence of a strong showing of clear abuse.' " (Id. at p. 735.) A record on appeal is often "cold," and it is "the trial court . . . that . . . is in the best position to judge defendant's demeanor." (Ibid.)

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Upon review, we must affirm the trial court's ruling if the record as a whole establishes defendant's request was properly denied on any ground. (People v. Dent (2003) 30 Cal.4th 213, 218 (Dent).)