The People, Plaintiff and Respondent v. Michael Ray Burgener, Defendant and Appellant

Summary

The court affirmed the death judgment after concluding that Burgener knowingly and intelligently waived counsel and that the trial court adequately warned him about the risks of self-representation. The court also held that the statutory requirement of counsel at all stages of preliminary and trial proceedings did not apply to the postverdict sentence-modification hearing, and that the trial court had discretion to permit self-representation there. Burgener forfeited his challenge to the trial court's treatment of a prior judge's factual findings, and in any event there was no reasonable probability of a different result. No separate opinions were filed.