Self-representation request; MCR 6.005(D)(1); People v Russell; People v Anderson; Disruption of proceedings; People v Hill; Substitute counsel; People v Traylor; Plain-error review; People v Carines

The court held that the trial court did not abuse its discretion by denying defendant’s midtrial request to represent himself because the request came after the jury was selected and sworn and self-representation would have “‘disrupt[ed], unduly inconvenience[d], or burden[ed] the Court in the administration of the Court’s business.’” Police went to defendant’s home to execute an arrest warrant, saw him carrying a rifle, and arrested him because he could not lawfully possess a firearm due to a prior felony. He was convicted by a jury of FIP and felony-firearm. The trial court found defendant competent twice before trial, then on the morning of trial defendant voiced dissatisfaction with the jury after selection and stated, “Yes, I’m moving to represent myself.” On appeal, the court held the trial court treated the request as unequivocal and substantially complied with MCR 6.005(D) by explaining the charges, maximum penalties, and that defendant would be held to the same standards as an attorney. It upheld the denial because the record supported the trial court’s finding that self-representation would be disruptive, noting defendant repeatedly interrupted, gave nonresponsive answers, and insisted he had no felony despite repeated explanations. It emphasized that it took “seven transcript pages” for defendant to answer whether he wanted to represent himself. The court also rejected the substitute-counsel claim because defendant never requested new counsel, did not show “good cause” such as a true breakdown in the attorney-client relationship, and counsel “diligently represented” him through objections and cross-examination. Further, replacement counsel after a sworn jury would have “unreasonably disrupt[ed] the judicial process.” Affirmed.