Cited by

The Minnesota Supreme Court has “held that the district court may rescind the pro se status of a defendant who ‘deliberately engages in serious and obstructionist misconduct’ and 15 [has] stated that the court cannot allow a defendant to use the right of self-representation to delay proceedings or to force a mistrial.” (quotation omitted).

The Minnesota Supreme Court has also explained that “the court cannot allow a defendant to use the right of self-representation to delay proceedings or to force a mistrial.”

See, d 186, 194 (Minn. 2003); Gustafson, d at 321; rev. denied (Minn. Apr.

Gustafson, d at 321; rev. denied (Minn. Apr.

Gustafson, d at 321; rev. denied (Minn. Apr.

“[A] defendant’s request for self-representation should be granted where it is clear, unequivocal, and timely and the defendant knowingly and intelligently waives his right to counsel.” (quotations omitted).

Faretta v. California, 422 U.S. 806, 814 (1975)

(declining to reach the merits of an ineffective-assistance-of-counsel claim because the record did not provide a sufficient basis to review appellant’s complaints).

Gustafson, d at 321; rev. denied (Minn. Apr.

When timely made, “the right to self-representation [i]s virtually absolute, subject only to the conditions necessary to a waiver of the right to assistance of counsel.” d 186, 191 (Minn. 2003) .

See State v. Christian , Gustafson, d at 321; rev. denied (Minn. Apr.

court erred by refusing to further continue the trial is partly based on his assertion that he had “an absolute right” to exercise his right to self-representation “because jury voir dire had not begun.” The right of self-representation has been described as “virtually absolute, subject only to the conditions necessary to a waiver of the right to assistance of counsel.”

Gustafson, d at 321; rev. denied (Minn. Apr.

4 We note that “claims that require a court to explore conversations between attorney and client are best handled on a petition for postconviction relief.” d 246, 255 (Minn. 2001); (“The preferred procedure is to raise the issue of ineffective assistance in a petition for postconviction relief in the district court.”); see also Minn. R. Crim.

Unlike cases in which a defendant requests to proceed pro se, or requests substitute 7 counsel, -79 (Minn. 1998), appellant requested neither.

d 186, 194 (Minn. 2003); see Dukes, d at 254-55 (remanding for postconviction proceeding when trial counsel did not impliedly concede the defendant’s guilt until closing argument, whether the defendant acquiesced to counsel’s statements was unclear, and the defendant’s ineffective-assistance-of-counsel claim was

See, n.1 (Minn. 1995) (explaining that direct appeal from a judgment of conviction is not the most appropriate way to raise an ineffective- assistance-of-counsel claim because the appellate court conseque

See, State v. Coe, 290 Minn. 537, 537−38

(deciding not to reach merits of appellant’s ineffective assistance of counsel claim where record did not provide sufficient basis for review).