California, United States of America
The following excerpt is from People v. Oberdiear, B287387 (Cal. App. 2020):
continuance." (People v. Jenkins, supra, 22 Cal.4th at 1039.) Similarly, when a defendant makes a midtrial motion to revoke his or her self-represented status and have counsel appointed for the remainder of the trial, the trial court has the discretion to manage an ongoing trial by conditioning the granting of the motion on no further delay. Here, with Oberdiear's several-year pattern of "demonstrable abuse" and "disruption" by changing counsel and his represented status, Oberdiear has not shown the trial court erred by giving him the option of continuing to represent himself or having standby counsel appointed. But, in either event, the trial would continue without interruption. Thus, the trial court did not abuse its discretion in indicating that it would deny Oberdiear's motion to withdraw his self-represented status for all the reasons it stated and at the same time advising Oberdiear that standby counsel could represent Oberdiear so long as the trial was not delayed. After an exhaustive discussion with the trial court, Oberdiear chose to have standby counsel represent him.