PEOPLE v. LAWRENCE
Where defendant waived his right to counsel and invoked his right to self representation after trial court adequately advised him of dangers and advised him he would be afforded no special treatment, and waiver form defendant completed notified him of his rights and warned him about disadvantages of self representation with specificity, defendant's waiver was knowing and voluntary. Where defendant changed his mind during jury selection and requested appointment of counsel at that time and also at close of jury selection, trial court abused its discretion in denying defendant's request at end of first day of trial. Trial court's error was structural and required reversal without analysis of prejudicial effect because deprivation of counsel at a critical stage of a criminal trial constitutes federal constitutional error affecting framework within which trial proceeds with consequences that are necessarily unquantifiable and indeterminate.
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