State v. Sheppard
In State v. Sheppard, 172 W.Va. 656, 310 S.E.2d 173 (W.Va. 1983), the Court concluded that an accused could exercise his right to self-representation, but recognized that the right was subject to reasonable restrictions.
As the Court stated in Syllabus Point 8 of Sheppard:
A defendant in a criminal proceeding who is mentally competent and sui juris, has a constitutional right to appear and defend in person without the assistance of counsel, provided that:
(1) he voices his desire to represent himself in a timely and unequivocal manner;
(2) he elects to do so with full knowledge and understanding of his rights and of the risks involved in self-representation;
(3) he exercises the right in a manner which does not disrupt or create undue delay at trial.