Espinoza

The unusual circumstances of this case present a cautionary tale for defendants who choose to represent themselves, for in the end, this defendant has no one but himself to blame for any failure to present a defense.

Defendant here waged a long campaign of manipulation and delay of his trial proceedings after being held to answer on a number of felony and misdemeanor charges. He was represented by seven different appointed counsel over the course of more than two years, largely due to how difficult a client he was. Over the same period, five different deputy district attorneys were assigned to handle the case. The case was set for trial numerous times, but defendant made repeated requests for continuances. Indeed, defendant’s case trailed for so long that there was concern over the continuing availability of witnesses.

When defendant’s jury trial finally commenced, defendant moved, during jury selection, to dismiss his latest public defender and represent himself pursuant to Faretta v. California (1975) 422 U.S. 806 [ 45 L.Ed.2d 562 , 95 S.Ct. 2525 ] (Faretta). In the course of providing defendant with the appropriate Faretta warnings, the court indicated it did not…