The People, Plaintiff and Respondent v. Zeferino Espinoza, Jr., Defendant and Appellant

Summary

The court held that the trial court properly continued defendant's already-commenced felony trial after finding that he voluntarily absented himself, even though defendant had waived counsel and was representing himself. The court also held that the trial court permissibly conditioned defendant's untimely self-representation request on his ability to proceed without an unreasonable continuance and did not abuse its discretion in denying a one-day continuance. The Court of Appeal's judgment was reversed, and the matter was remanded for consideration of defendant's remaining appellate claims.