People v. Maddox

In People v. Maddox (1967) 67 Cal.2d 647, at the time he entered his plea, the defendant had requested self-representation, but his request was denied. On the morning trial began, the trial court changed its mind and allowed the defendant to represent himself, but refused to grant a continuance so he could obtain witnesses and prepare a defense. Maddox held the trial court had erred by denying the defendant's earlier self-representation request. (Id. at p. 651.) Therefore, it reasoned, "the dispositive question . . . was whether defendant was entitled to a reasonable continuance at that point to prepare himself for trial." (Id. at p. 652.) Maddox explained that a defendant, like an attorney, had to be given a reasonable opportunity to prepare a defense. Moreover, the defendant had not been given the statutorily - required five days to prepare for trial ( 1049), an error of constitutional dimension. (Id. at p. 653.) Maddox explained that to deny a reasonable continuance would "render his right to appear in propria persona an empty formality." (Id. at p. 653.)