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Name: People v. Williams
Case #: D039730
Court: CA Court of Appeal
District 4 DCA
Division: 1
Opinion Date: 08/01/2003

Because a mentally disordered offender commitment proceeding is civil in nature and provides for treatment, not punishment, Williams had no constitutional right to represent himself. However, because he had a statutory right to counsel, Williams could refuse counsel and represent himself, but such a right was governed only by due process principles. Here the court afforded him a hearing on the issue, but denied the request due to the severity and complexity of the issue. Moreover, any error in denying him the right to self-representation was harmless, because the request for self-representation concerned a desire to present inadmissible evidence. Finally, even if Faretta principles applied, the court did not err because the request for counsel was equivocal.