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Name: People v. Koontz
Case #: S036450
Court: CA Supreme Court
District CalSup
Opinion Date: 05/09/2002
Subsequent History: Rehrg. den. 7/17/02

The trial court did not err by allowing appellant to represent himself. The record did not demonstrate that appellant’s mental illness rendered him unable to make a knowing and voluntary waiver of counsel after adequate admonitions. The fact that appellant “took missteps” in his self-representation reflected his lack of legal knowledge, not necessarily mental illness or incompetence.