Appellate Division of the Supreme Court of the State of New York February 21, 2012 (People v. Littlejohn)

The Supreme Court did not err in denying the defendant’s application to proceed pro se. A criminal defendant has a constitutional right to self-representation (see Faretta v California, 422 US 806, 814 [1975]; Matter of Kathleen K [Steven K.], 17 NY3d 380, 384-385 [2011]; People v McIntyre, 36 NY2d 10, 14-15 [1974]). However, the right to self-representation is “not . . .