People v. Burden

Defendant was convicted of two counts of armed robbery, MCL 750.529; MSA 28.797, after a jury trial in September, 1983. Defendant was sentenced to concurrent prison terms of 60 to 100 years, with a recommendation of no parole. Defendant appeals to this Court as of right.

Defendant’s first claim is that the trial court erred in finding the defendant competent to represent himself. A criminal defendant’s right to proceed in propria persona is guaranteed by the Michigan Const 1963, art 1, § 13 and by MCL 763.1; MSA 28.854. The right to self-representation is implicitly guaranteed by the Sixth…