The People, Plaintiff and Respondent v. Franklin Lynch, Defendant and Appellant — Moreno, J., Dissenting

Summary

The dissent would reverse because the defendant's unequivocal, knowing, voluntary, intelligent, and non-dilatory requests for self-representation were made weeks before pretrial proceedings and months before jury selection. It would apply a time-focused reasonable-time rule rather than a totality-of-the-circumstances test incorporating case complexity, witness availability, counsel readiness, and other factors. Because this is a dissent, it has no controlling holding; the dissenting justice would have found the denial of self-representation reversible per se.