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nduct fits well within the supreme court’s definition of “waiver by conduct,” which has been applied in a different context to criminal defendants who seek to frustrate or delay court proceedings by “voluntarily engag[ing] in misconduct knowing what they stand to lose.” (quotation omitted) 10 (alteration added); see also State v. Worthy , -77 (Minn. 1998) (concluding that defendants waived right to counsel by firing attorney).

See Maddox, d at 147; (inferring waiver after defendants fired their court-appointed attorneys); -13 (Minn. 1990) (inferring waiver from the “[d]efendant’s interaction with 12 different judges, his letters to those judges, his various conversations with two different public defender

“Criminal defendants have a constitutional right to an attorney and a corollary constitutional right to choose to represent themselves in their own trial.”

An indigent defendant is entitled to court-appointed counsel, Gideon v. Wainwright, 372 U.S. 335, 339-45 (1963), but “does not have the unbridled right to be represented by the attorney of [their] choice.”

When accepting a waiver of counsel, district courts “should comprehensively examine the defendant regarding the defendant’s comprehension of the charges, the possible punishments, mitigating circumstances, and any other facts relevant to the defendant’s understanding of the consequences of the waiver.” (citation omitted) (internal quotation marks omitted).

See, n.7 (Minn. 1998) (“Under certain circumstances, a trial court may refuse a defendant’s request to proceed pro se, where a defendant has waived or forfeited the right to self-representation.”).

279 (Minn. 1998); (discussing defendant’s constitutional right to be present at trial).

However, this right does not give indigent defendants an “unbridled right to be represented by the attorney of their choice,” and “[a] [district] court will grant an indigent[] [defendant’s] request for different counsel only if exceptional circumstances exist and the demand is timely and reasonably made.” (quotation omitted).

In State v. Worthy , the defendants fired their attorneys the morning of trial and argued on appeal “that their waivers of their right to an attorney were invalid.” d 270, 274-75 (Minn. 1998).

The circumstances to be considered “includ[e] the background, experience, and conduct of the accused.” -76 (Minn. 1998) (quotation omitted).

“Criminal defendants have a constitutional right to an attorney and a corollary constitutional right to choose to represent themselves in their own trial.” (citing Faretta v. California, 422 U.S. 806, 819-21 (1975)).

Appellate courts “will only overturn a trial court’s finding of a valid waiver of a defendant’s right to counsel if that finding is clearly erroneous.”

A defendant is entitled to the appointment of substitute counsel “only if exceptional circumstances exist and the demand is timely and reasonably made .” ().

12 –76 (Minn. 1998); Minn. R. Crim.

To ensure that a waiver is valid, the district court “should comprehensively examine the defendant regarding the defendant’s comprehension of the charges, the possible punishments, mitigating circumstances, and any other facts relevant to the defendant’s understanding of the consequences of the waiver.” (quotation omitted); (reversing probation revocation when “the record offer[ed] no indication that [the probationer] knowingly and intelligently waived the right to counsel”).

d 270, 275-76 (Minn. 1998).

Whether a defendant’s decision to waive counsel was valid depends on “the particular facts and circumstances surrounding the case, including the background, experience, and 6 conduct of the accused.” -76 (Minn. 1998) (quoting Johnson v. Zerbst, 304 U.S. 458, 464 (1938)).

The validity of a waiver “depends ‘upon the particular facts and circumstances surrounding that case, including the background, experience, and conduct of the accused.’” -76 (Minn. 1998) (quoting Johnson v. Zerbst, 304 U.S. 458, 464 (1938)).

Whether a right-to- counsel waiver is valid depends on “the particular facts and circumstances surrounding that case, including the background, experience, and conduct of the accused.” -76 (Minn. 1998) (quotation omitted).

While Carlson’s drug convictions span over 30 years, the career-offender statute “does not impose a time limit for includable prior convictions.”

“Whether a waiver of a constitutional right is valid depends upon the particular facts and circu mstances surrounding that case, including the background, experience, and conduct of the accused.” -76 (Minn. 1998) (quotation omitted); see Rhoads, d at 886 (stating that the lack of an “on-the-record inquiry regarding waiver .

“We review a finding that a defendant validly waived his right to counsel for clear error.” ().

16 “We will only overturn a ‘finding of a valid waiver of a defendant’s right to counsel if that finding is clearly erroneous.’” ().

The district court will grant a defendant’s request for substitute counsel “only if exceptional circumstances exist and the demand is timely and reasonably made.” (quotation omitted).

A district court must also inform a defendant of the “dangers and disadvantages of self- representation.” (quotation omitted).

Whether a waiver of the constitutional right to counsel is valid “depends ‘upon the particular facts and circumstances surrounding that case, including the background, experience, and conduct of the accused.’” -76 (Minn. 1998) (quoting Johnson v. Zerbst, 304 U.S. 458, 464 (1938)).

The validity of the waiver of the right to counsel depends on “the particular facts and circumstances surrounding that case, including the background, experience, and conduct of the accused.” 75-76 (Minn. 1998) (quotation omitted).

Whether the waiver of the right to counsel is valid depends on “the particular facts and circumstances surrounding that case, including the background, experience, and conduct of the accused.” -76 (Minn. 1998) (quotation omitted).

A defendant’s request for substitute counsel must be “timely and reasonably made.”

See State v. Sanders , (holding appellant was not prejudiced by denying continuance request when the court had granted two motions for continuance); (concluding that district court properly denied request to substitute counsel on the first day of trial); (concluding the distr ict court properly denied a continuance request after defendant had already received five continuances).

does not require reversal when the particular facts and circumstances of the case demonstrate a valid waiver.” (quoting Rhoads , d at 886)

The district court should appoint substitute counsel “ only if exceptional circumstances exist and the demand is timely and reasonably made.” (quotation omitted).

Faretta v. California, 422 U.S. 806, 807 (1975)

Faretta v. California , 422 U.S. 806, 807 (1975)

d 270, 278-79 (Minn. 1998) ; see also State v. Clark , (holding that the defendant ’s request for substitute counsel was untimely when the request was made the morning that trial was to begin, after jury selection had begun, and when the defendant had made a speedy -trial demand) .

When a defendant raises complaints about the effectiveness of appointed counsel ’s representation, the district court should only appoint substitute counsel “if exceptional circumstances exist and the demand is timely and reasonably made.” (citation omitted).

2 The validity of a waiver “depends upon the particular facts and circumstances surrounding [ the] case, including the background, experience, and conduct of the accused.” State v. Rhoads , ( -76 (Minn. 1998)) (other quotation omitted) .