Ethics

Opinion.  Some interesting grafs:

In line with that precedent, we have recognized that "[t]here are times when the criminal justice system would be poorly served by allowing the defendant to reverse his course at the last minute and insist upon representation by counsel." Menefield, 881 F.2d at 700. A continuance may be denied even where it results in the defendant being unrepresented at trial. United States v. Thompson, 587 F.3d 1165, 1174 (9th Cir. 2009) (listing factors to be balanced when a decision to grant or deny a continuance implicates a defendant's Sixth Amendment right to counsel, including "whether the continuance would inconvenience witnesses, the court, counsel, or the parties; [ ] whether other continuances have been granted; [ ] whether legitimate reasons exist for the delay; [ ] whether the delay is the defendant's fault; and [ ] whether a denial would prejudice the defendant"), citing United States v. Studley, 783 F.2d 934, 938 (9th Cir. 1986) andUnited States v. Leavitt, 608 F.2d 1290, 1293 (9th Cir. 1979); see also Faretta, 422 U.S. at 852 (Blackmun, J., dissenting) (pointing out the procedural dilemmas raised by the self-representation rule).

The court of appeal reasonably concluded, therefore, that the trial court did not abuse its discretion in denying the requested continuance. Cf. Marshall v. Taylor, 395 F.3d 1058, 1061-62 (9th Cir. 2005) (regarding timeliness element in Faretta request).