People v. Bulls CA4/1, D077170

Defendant Shonnel Rashawn Bulls was charged with residential burglary and petty theft after surveillance and body-worn camera (BWC) footage linked him to a motel and a later room entry where items were taken.
Officer Howard identified Bulls after comparing BWC and surveillance footage; Bulls admitted entering the room but claimed he was tricked and denied intent to burglarize.
Bulls initially had counsel, sought a Marsden hearing, then elected to represent himself; Judge Amador warned him about risks of self-representation but allowed it.
While proceeding pro per, Bulls filed multiple pretrial motions and repeatedly displayed misunderstanding of legal procedures and discovery rules, interrupting judges and rearguing resolved points.
On the day trial was to begin, before jury selection, Bulls asked the court to appoint counsel; Judge Lewis made blunt critical remarks about Bulls’ legal competence but ultimately granted the request, delaying trial.
Bulls was tried under newly appointed counsel, convicted on both counts, and appealed claiming Judge Lewis’ comments coerced him into relinquishing his right to self-representation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Judge Lewis’s disparaging pretrial remarks coerced Bulls to abandon his right to self-representation	Court’s comments were not coercive; they occurred pretrial, Bulls repeatedly stated he lacked legal understanding, and appointment was permitted under caselaw	Judge’s harsh, meanspirited remarks pressured and coerced Bulls to request counsel, violating his right to self-representation	Court affirmed: remarks were noncoercive educational/rebuking comments made before jury selection; Bulls sought counsel because he lacked legal competence, so no misconduct or prejudice was shown

People v. Marsden, 2 Cal.3d 118 (procedure for replacing appointed counsel)
People v. Snow, 30 Cal.4th 43 (standard for evaluating judicial conduct and prejudice)
People v. Sturm, 37 Cal.4th 1218 (judicial remarks to a jury can create bias)
People v. Banks, 59 Cal.4th 1113 (importance of whether jury heard judicial comments)
People v. Abel, 53 Cal.4th 891 (pretrial comments not heard by jury cannot influence jury)
People v. Nieves, 11 Cal.5th 404 (contrast between persistent biased remarks to jury and occasional impatience)
Victaulic Co. v. American Home Assurance Co., 20 Cal.App.5th 948 (judicial mocking of a witness before jury is misconduct)
Barrientos v. City of Los Angeles, 30 Cal.App.4th 63 (court may not compel litigants to settle or coerce rights)