The People, Plaintiff and Respondent v. Frank Kalil Becerra, Defendant and Appellant

Summary

The court held that the trial court improperly terminated Becerra’s constitutional right to represent himself because the record did not support the finding that his discovery requests and continuances were deliberately dilatory or obstructive. The trial court failed to warn Becerra, consider alternative sanctions, explain how his conduct threatened trial integrity, or create an adequate record for review. Because erroneous revocation of self-representation is reversible per se, the judgment was reversed in its entirety.