Bey

DISCUSSION

I. The Trial Court Did Not Abuse Its Discretion by

Revoking Appellant’s Propria Persona Status A. Relevant background Prior to the preliminary hearing, the superior court granted appellant’s request to proceed in propria persona, but advised appellant that “self-representation is almost always an unwise choice,” and he would “be held to the same standards of conduct as an attorney.” Thereafter, appellant represented himself at the preliminary hearing and throughout the pretrial proceedings. On August 1, 2023, appellant made his first appearance in the trial court and filed a motion to dismiss pursuant to rule 12(b)(2) of the Federal Rules of Criminal Procedure. Appellant offered no argument on the motion, but advised the court he did not understand the nature and cause of the charges against him, and objected to the prior court’s entry of a not guilty plea on his behalf. The trial court explained the charges and reminded appellant that if he was going to proceed in propria persona, he would be presumed to understand the law. He would not receive any special treatment, and would be treated like any attorney

3 appearing before the court. Appellant declined the…