In State v. Fritz the Washington Court of Appeals held that although a criminal defendant has the right to waive counsel and to proceed pro se, this right is not unqualified. Such waiver of counsel, if denied by the trial court, will not automatically result in reversible error where the trial court finds that the judicious and orderly administration of justice demands observance of certain procedural requirements. The court's holding represents an erosion of an accused's right to conduct his own defense.
- criminal law; pro se representation
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