Garrison v. State
In Garrison v. State, 762 P.2d 465 (Alaska App. 1988), the Court drew a distinction between pro se defendants seeking the guidance or input of stand-by counsel, and defendants who are represented by counsel and who seek to act as a substitute for their attorney during portions of the case.
In Garrison, the Court held that defendants in this latter situation have a significantly lesser need for hybrid representation -- and that this is a factor that a trial judge can properly consider when ruling on the defendant's request. Garrison, 762 P.2d at 467.
Garrison also acknowledged that a defendant's co-participation in the trial process was potentially disruptive to the proceedings. Ibid.