In People v. Carson (2005) 35 Cal.4th 1, a trial court revoked a defendant's right of self-representation based on a defendant's out-of-court conduct relating to discovery matters. A jury convicted the defendant of, inter alia, murder, and he appealed. Carson held that, consistent with Faretta v. California (1975) 422 U.S. 806, a trial court may revoke a defendant's right of self-representation for misconduct that seriously threatens the core integrity of the trial, whether or not that misconduct occurs in the courtroom. (Carson, supra, at p. 6.) Carson stated the right of self-representation is not a license to abuse the dignity of the courtroom, or a license not to comply with relevant rules of procedural and substantive law. (Carson, supra, 35 Cal.4th at p. 8.) Carson observed that the relevant rules of procedural and substantive law are not limited to those relating solely to the trial itself. (Id. at p. 9.) In People v. Welch (1999) 20 Cal.4th 701, the California Supreme Court noted that a condition precedent to a defendant's exercise of the right of self-representation is the defendant is able and willing to abide by rules of procedure and courtroom protocol. (Id. at p. 734.) A self-representing defendant should not be allowed by disruptive conduct to "bring his trial to a standstill." (Ibid.) "Ultimately, the effect, not the location, of the misconduct and its impact on the core integrity of the trial will determine whether termination is warranted." (Carson, supra, 35 Cal.4th at p. 9.) Carson observed that "when a defendant exploits or manipulates his in propria persona status to engage in threatening or intimidating . . . acts, wherever they may occur, the trial court does not abuse its discretion in determining he has forfeited the right of continued self-representation." (Carson, supra, 35 Cal.4th at p. 9.) Carson affirmed the appellate court's reversal of the conviction and remanded the matter to the trial court for, inter alia, reconsideration in light of criteria which Carson articulated for use by trial courts deciding whether to revoke a defendant's right of self-representation. (Id. at p. 13.)