People v. Ramos

Opinion

ZELON, Acting P. J.

Rafael Ramos was charged with making criminal threats against Nancy Garcia, and elected to represent himself at trial. Prior to opening statements, the trial court removed Ramos from the courtroom for disruptive conduct. No standby counsel was appointed to represent him in his absence. During Ramos’s period of exclusion, the prosecution presented its opening statement and conducted a direct examination of Garcia. Ramos was then permitted to return to the courtroom and participate in the remainder of trial. The jury found him guilty.

On appeal, Ramos argues that (1)…