People v. Watkins CA2/2

DISCUSSION

I. Self-representation

Nearly eight months after his initial appearance in court and just minutes before the jury pool was to arrive in the courtroom, defendant announced for the first time that he wanted to represent himself. The trial court informed him that his request would be untimely unless he was ready to proceed to trial immediately. Although defendant initially said he was “ready to go forward,” he next stated that there were “a lot of things [he] need[ed] to do.” Defendant also indicated that he had not received any discovery for his case. When the trial court told him it would not grant a continuance and again asked if he was ready to proceed without one, defendant asked if the court was “gonna force [his] hand.” The trial court then declared that the request was untimely and denied it. A criminal defendant has the constitutional right to forego the constitutional guarantee of assistance of counsel and to represent himself at trial. (Faretta v. California (1975) 422 U.S. 806, 817-818.) But this right is “‘not absolute.’” (People v. Boyce (2014) 59 Cal.4th 672, 702 (Boyce), quoting Indiana v. Edwards (2008) 554 U.S. 164, 171.) When a defendant invokes…