LaFleur v. State

AFFIRMED. 1 See Jones v. State, 449 So.2d 253, 259 (Fla.1984) (“[T]he right to appointed counsel, like the obverse right to self-representation, is not a license to abuse the dignity of the court or to frustrate orderly proceedings, and a defendant may not manipulate the proceedings by willy-nilly leaping back and forth between the choices.”).

EVANDER, BERGER and WALLIS, JJ., concur.. Although it was error for the trial court to require LaFleur to present his request for self-representation in writing, see, e.g., Combs v. State, 133 So.3d 564, 566 (Fla. 2d DCA 2014), the error was harmless…