Guerrina v. State

By the Court, STIGLICH, J.:

In this appeal, we first determine whether a criminal defendant's request to represent himself was properly denied as "untimely" when the request was made 24 days prior to the scheduled trial date. We conclude that, under Lyons v . State ,1 such a request may be denied as untimely if granting it will delay trial. We further conclude that Lyons is consistent with United States Supreme Court precedent and decline to overrule it. We therefore affirm the district court's denial of Robert Guerrina's request to represent himself.

Next, we consider whether the State…