State v. Buelna

Reubin Buelna appeals his jury convictions for attempting to elude, second degree assault, and first degree malicious mischief. We hold that a request to proceed pro se with "standby counsel” requires the court to advise the defendant of the nature and seriousness of the charges and the possible penalties before granting the request. We reverse and remand for a new trial because the trial court did not explain sufficiently the risks of self-representation.

The charges arose out of an incident on August 1, 1994. A Vancouver police officer tried to stop a car for a traffic violation. The car…