It's farily rare that I agree with every single word of an opinion of the California Supreme Court. It's rarer still for me to agree with every word written by Justice Brown. But this is one of the rare exceptions.
Justice Brown holds that under certain circumstances, a defendant's right to represent himself can be taken away based upon conduct that occurs outside of the courtroom. The opinion contains measured, temperate language, with important caveats. I completely agree with Justice Brown's analysis, including her decision that -- on the (incomplete) record before her -- it was unclear whether defendant's conduct was sufficiently severe to justify termination of his right to represent himself, thereby justifying a remand.
This is the kind of nuanced, careful analysis that I wish was a bit more prevalent from the Cal Supremes.
