State prisoner Cooks appeals from the district court’s judgment denying his petition for a writ of habeas corpus. He argues that the California Court of Appeal unreasonably applied Faretta v. California, 422 U.S. 806 , 95 S.Ct. 2525 , 45 L.Ed.2d 562 (1975), and Gideon v. Wainwright, 372 U.S. 335 , 83 S.Ct. 792 , 9 L.Ed.2d 799 (1963), when it affirmed his robbery convictions. Cooks contends that the state trial court should not have consolidated two separate criminal cases in which he was a defendant, representing himself in one case and represented by counsel in the other. He asserts that this improperly forced him to choose between invoking his constitutional right to self-representation, as recognized in Faretta , or his Gideon right to counsel on both charges. The district court had jurisdiction pursuant to 28 U.S.C. § 2254 , and we have jurisdiction over this timely appeal pursuant to 28 U.S.C. § 2253 . We affirm.

Cooks robbed James Fleming and Ignacio Suarez separately. The two robberies were conducted within 15 days under similar circumstances: both involved the use of a gun, both occurred in daylight, and both victims had just with drawn cash from the same bank branch.

Fleming identified Cooks from a photographic lineup, and the State of California charged Cooks with robbery (Fleming Case). Cooks was granted permission to represent himself.

Suarez also identified Cooks from a photographic lineup. The state charged Cooks with robbery in a separate case (Suarez Case). A public defender was appointed.

The Fleming Case and the Suarez Case initially proceeded separately, with Cooks representing himself in the former and represented by appointed counsel in the latter. The state moved to consolidate the two cases. See Cal.Penal Code § 954 (“An accusatory pleading may charge two or more different offenses connected together in their commission, or different statements of the same offense or two or more different offenses of the same class of crimes or offenses, under separate counts, and if two or more accusatory pleadings are filed in such cases in the same court, the court may order them to be consolidated”). Cooks objected to consolidation, ar guing that it would “improperly force him to choose between giving up his right to represent himself in the Fleming[C]ase or giving up his right to appointed counsel in the Suarez[C]ase.” The trial court consolidated the cases over Cooks’ objection, and told Cooks that he would have to decide whether to represent himself or proceed with counsel in the consolidated case.

Cooks initially chose the public defender but later decided to represent himself, which he did throughout the trial.

A jury convicted Cooks of both robberies. Cooks appealed on a number of grounds, including that the consolidation motion was improperly granted, but the California Court of Appeal affirmed his conviction. With respect to Cooks’ objection to the consolidation, the Court of Appeal stated:

After the California Supreme Court summarily denied Cooks’ petition for review, Cooks filed a federal petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2254 , alleging that “[t]he trial court violated petitioner’s constitutional rights by consolidating two separate cases, one where he represented himself and one where he was represented by appointed counsel, and forcing petitioner to choose between representing himself on both charges or being represented by the public defender’s office on both charges.” The district court denied Cooks’ petition.

II.

We review the district court’s judgment denying Cooks’ application for a writ of habeas corpus de novo. See Nulph v. Cook, 333 F.3d 1052, 1056 (9th Cir.2003). Pursuant to 28 U.S.C. § 2254 (d)(1):

The Supreme Court has explained the meaning of the statutory phrases “clearly established,” “contrary to,” and “unreasonable application,” as follows:

Lockyer v. Andrade, 538 U.S. 63, 71-72, 73, 75 , 123 S.Ct. 1166 , 155 L.Ed.2d 144 (2003) (internal quotations, alterations, and citations omitted).

In this case, the relevant “clearly established” Supreme Court law is Faretta v. California and Gideon v. Wainwright. Faretta held that a criminal defendant has a Sixth Amendment right to represent himself. 422 U.S. at 807 , 95 S.Ct. 2525 . Gideon held that the Sixth Amendment requires the state to appoint counsel for indigent criminal defendants. 372 U.S. at 343-45, 83 S.Ct. 792 . As the Court has stated, “the right to self-representation is not absolute.” Martinez v. Court of Appeal, 528 U.S. 152, 161 , 120 S.Ct. 684 , 145 L.Ed.2d 597 (2000). That right cannot be “a license not to comply with relevant rules of procedural and substantive law,” and a trial court may terminate self-representation where a defendant “deliberately engages in serious and obstructionist misconduct.” Faretta, 422 U.S. at 834 n. 46, 95 S.Ct. 2525 . The trial court may also, “even over objection by the accused — appoint a ‘standby counsel’ to aid the accused.” Id. Standby counsel may then participate in trial proceedings, without the express consent of the defendant, so long as the participation does not “seriously undermine[]” the “appearance before the jury” that the defendant is proceeding pro se. McKaskle v. Wiggins, 465 U.S. 168, 187 , 104 S.Ct. 944 , 79 L.Ed.2d 122 (1984). Therefore, “the government’s interest in ensuring the integrity and efficiency of the trial at times outweighs the defendant’s interest in acting as his own lawyer.” Martinez, 528 U.S. at 162 , 120 S.Ct. 684 .

The state court’s decision was not “contrary to” Faretta or Gideon. As Cooks concedes, neither of those cases, nor any other Supreme Court decision, “holds that the right to an attorney or the right to represent oneself prevents a joinder of two separate cases.” The state court therefore did not “ ‘appl[y] a rule that contradicts the governing law set forth in [the Supreme Court’s] cases.’ ” Lockyer, 538 U.S. at 73 , 123 S.Ct. 1166 , quoting Williams v. Taylor, 529 U.S. 362, 405-06 , 120 S.Ct. 1495 , 146 L.Ed.2d 389 (2000).

The next issue is whether the California Court of Appeal decision rejecting Cooks’ claim was an “unreasonable application” of Faretta or Gideon. Cooks concedes that if the two charges had been brought initially in a single case, he would have no unqualified right to compel severance so that he could represent himself on one count and have counsel on the other. He also does not argue that the consolidation caused him prejudice. However, he contends that once the state chose to proceed against him in two separate cases, and he invoked Faretta in one case and Gideon in the other, it was objectively unreasonable for the state court to conclude that Faretta and Gideon did not preclude consolidation, regardless of prejudice.

That Cooks could not exercise his Faret-ta right in the Fleming Case without giving up his Gideon right in the Suarez Case, and vice versa, does not render the state court’s action constitutionally impermissible. As we stated in the con text of a challenge to the voluntariness of a waiver of the right to counsel, “there is no authority for the proposition that [a defendant] is entitled to an absolutely unconditional choice between exercising his right to counsel and his right to self-representation.” United States v. Robinson, 913 F.2d 712, 715 (9th Cir.1990).

Indeed, Cooks recognizes as much. At oral argument, Cooks’ counsel conceded that if the state, instead of moving to consolidate, had voluntarily dismissed both cases without prejudice and filed a new indictment including both counts, no Faret-ta or Gideon problem would have arisen. Cooks’ argument, then, is not that the state could not seek to combine the two cases, but just that it could not do so through a consolidation motion. The California Court of Appeal was not objectively unreasonable in concluding that the principles established in Faretta and Gideon do not turn on such procedural niceties.

AFFIRMED.