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Name: People v. Watts
Case #: C056491
Court: CA Court of Appeal
District 3 DCA
Opinion Date: 04/29/2009

A request for self-representation is predicated on its timeliness, as well as the defendant’s ability and willingness to abide by rules of procedure and courtroom protocol. In reviewing the denial of a defendant’s Faretta request for self-representation (Faretta v. California (1975) 422 U.S. 806), the reviewing court reviews the entire record. In this case, it was questionable whether appellant’s Faretta request was unequivocal and not merely a function of pique. Regardless, appellant’s demonstrated inability to conform his behavior to rules of courtroom protocol, as reflected in the record, justified the trial court’s denial of the Faretta request. In affirming the trial court ruling, the appellate court noted that it was relevant to consider defendant’s entire pretrial conduct rather than only his conduct at trial. It would be nonsensical and a waste of resources to proceed to trial before determining a Faretta request when defendant’s pretrial conduct makes it clear he is unable to conform to rules and procedure.