People v. Rodriguez-Arada

Defendant appealed his conviction of first-degree murder relating to the stabbing death of his wife arguing that the trial court erred in denying his request to represent himself and for leaving him shackled during the trial. The appellate court reversed, finding that defendant’s request to represent himself was clear and unequivocal, that his lack of proficiency in English was not a basis to deny self-representation, and defendant’s conduct was not so egregious to forfeit his right to self-representation. The appellate court also found that the trial court erred in leaving defendant partially shackled during trial. (ZENOFF and BIRKETT, concurring)