People v. Talidis

Defendant was found guilty of driving while his license was revoked. The issue before the court on appeal was whether the trial court denied defendant’s right to a fair trial when it appointed standby counsel to conduct defendant’s trial and denied her request for a continuance after defendant elected to proceed pro se and then refused to participate in the trial. The appellate court affirmed, finding that the trial court was within its discretion in terminating defendant’s right to represent himself or when it elevated counsel from standby counsel to counsel of record when defendant did not appear for his trial. The appellate court also found that the trial court did not abuse its discretion when it denied counsel’s motion for a continuance as she had sufficient time to prepare for the trial, taking into consideration the lack of complexity of the charge and the limited number of witnesses. (SCHOSTOK and KENNEDY, concurring)