People v. Windham

Opinion

WRIGHT, J., *

Contrary to an earlier conclusion reached by this court in People v. Sharp (1972) 7 Cal.3d 448 [103 Cal.Rptr. 233, 499 P.2d 489], the United States Supreme Court has held that a defendant in a state criminal trial has a federal constitutional right to represent himself without counsel if he voluntarily and intelligently elects to do so. (Faretta v. California (1975) 422 U.S. 806 [45 L.Ed.2d 562, 95 S.Ct. 2525].) We are now called upon to determine how the high court’s mandate will be implemented, specifically—prior to what point during pending criminal proceedings must the…