In People v. Fraser (2006) 138 Cal.App.4th 1430, the Court of Appeal held that a defendant has no right to self-representation in an SVPA trial. The court concluded there is no constitutional right to self-representation in a civil commitment proceeding under the SVPA, under either the rationale of Faretta v. California (1975) or the due process clause of the United States Constitution. (138 Cal.App.4th at p. 1444.) The appellant in Fraser cited no direct authority to support application of the Faretta right to self-representation to a civil commitment proceeding under the SVPA. He also acknowledged that the only decision on the issue, People v. Leonard (2000) 78 Cal.App.4th 776, 784, merely assumed without deciding that individuals subject to the SVPA are to receive the same constitutional protections accorded criminal defendants, including the right to self-representation. (Fraser, supra, 138 Cal.App.4th at p. 1444.) Fraser based his claim to a right to self-representation on the Faretta rationale of respect for the individual and the Sixth Amendment right to make one's own defense. (Fraser at p. 1445.) Self-representation is required, he argued, to ensure a defendant is able to present a defense of his own choosing. The Fraser court observed that the United States Supreme Court has not extended the right to self-representation under Faretta to proceedings other than criminal prosecutions. It cited Martinez v. Court of Appeal of Cal. Fourth Appellate Dist. (2000), in which the court declined to extend the right to appeal from a criminal conviction. (Fraser, supra, 138 Cal.App.4th at p. 1445)