People v. Baker CA2/2, B325893

Tommie Lee Baker was convicted in 2007 of attempted murder and multiple counts of attempted carjacking, receiving a sentence of 58 years to life as a second strike offender.
Following prior appeals and remands for resentencing due to sentencing errors, Baker ultimately received a reduced sentence of 20 years, 8 months plus 25 years to life, reflecting changes in the law and acknowledged mitigation.
Baker repeatedly requested to represent himself (Faretta motions) at various stages during resentencing proceedings, which were complicated by questions regarding his mental competency and repeated appointment and withdrawal of multiple counsel.
The court suspended proceedings when doubts about Baker’s mental competence were raised, later finding him competent after evaluation delays largely attributed to defense requests and Baker's conflicts with his attorneys.
Upon being declared competent, Baker did not renew his Faretta motion to represent himself at the resentencing hearing; he was represented by counsel, who advocated for mitigation and resentencing, and Baker remained silent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Denial of right to self-representation at resentencing	Baker abandoned any Faretta motion and failed to renew it	The trial court erred by not reinstating his pro. per. status automatically	No violation; Baker abandoned the request
Timeliness and handling of competency proceedings	Proceedings followed required protocol due to competence doubt	Delays and confusion infringed Baker’s rights to autonomy	No abuse; delays justified and attributable to defense
Need for court to sua sponte reinstate self-representation	No duty to reinstate without express, renewed request	Court was obliged to reinstate pro. per. status upon competence finding	No duty absent renewed explicit request
Resulting prejudice or structural error	No prejudice—Baker received a benefit from counsel advocacy	Errors were structural and require reversal regardless of outcome	No structural error or prejudice demonstrated

Faretta v. California, 422 U.S. 806 (1975) (establishes the constitutional right of self-representation)
Godinez v. Moran, 509 U.S. 389 (1993) (competence standard applies to waivers of counsel)
People v. Watson, 46 Cal.2d 818 (Cal. 1956) (harm/prejudice standard for reversals on appeal)
People v. Marsden, 2 Cal.3d 118 (Cal. 1970) (sets procedure for requesting substitution of counsel)
Pate v. Robinson, 383 U.S. 375 (1966) (competency to stand trial is required under due process)
People v. Denham, 2 Cal.3d 557 (Cal. 1970) (abuse of discretion review standard)