P. v. Doss CA1/4
This case comes to us a second time on appeal following a decision by the trial court on remand in response to our opinion in People v. Doss (2014) 230 Cal.App.4th 46 (Doss I), which conditionally reversed an order revoking Doss’s self-representation under Faretta v. California (1975) 422 U.S. 806 (Faretta). The trial court, we said in Doss I, had applied an incorrect legal standard. (Doss I, at p. 55.) The correct standard, articulated in People v. Carson (2005) 35 Cal.4th 1, 10–11 (Carson), allows for revocation only if the defendant has engaged in “ ‘obstructive behavior [that] seriously threatens the core integrity of the trial.’ ” (Doss I, at p. 55, quoting Carson, at pp. 10–11.) On remand, the court again revoked Doss’s Faretta status, this time applying the Carson standard, and reinstated the prior judgment. On appeal, Doss claims the court still did not comply with the Carson standard. We disagree and will affirm.
Comments on P. v. Doss CA1/4