People v. BRANTE

Opinion by Judge WEBB.

Whether the Sixth Amendment right to counsel requires that a pro se defendant who voluntarily absents himself from his criminal trial — as contrasted with such a defendant who is held to have waived the right of self-representation by engaging in disruptive behavior — be appointed counsel during his absence has not been decided by the United States Supreme Court and is unresolved in Colorado. We conclude that the trial court’s failure to direct advisory counsel to take control of the case when defendant, Michael Alan Brante, voluntarily absented himself did not violate…