People v. Ruffin, B270940

Elijah Ruffin was charged with corporal injury to a cohabitant and assault likely to produce great bodily injury based on a single incident; two prior strike convictions and two prior prison-term allegations were pled, exposing him to an aggregate potential sentence of roughly 27 years to life.
On the last day set for trial in master calendar court, appellant insisted on proceeding despite his appointed counsel being engaged in another trial; he signed and initialed a written Faretta advisement/waiver form and the court granted his request to represent himself.
The master calendar court’s on-the-record colloquy consisted mainly of asking whether Ruffin had initialed/signed the form and whether he had questions; the form left blanks and contained ambiguities about the specific charges and did not state the possible maximum sentence.
At trial before a different judge, Ruffin expressed reluctance and asked for time to prepare and for counsel, but the trial court declined and trial proceeded; Ruffin was convicted on both counts and sentenced.
On appeal the court reviewed the entire record de novo and concluded the waiver was invalid because the master calendar court failed to ensure Ruffin understood the dangers and disadvantages of self-representation and did not resolve ambiguities about the charges or inform him of the potential penal consequences.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the master calendar court adequately ensured a knowing, intelligent, and voluntary Faretta waiver	The People argued the written waiver plus appellant’s initials/signature and brief colloquy sufficed to show a knowing waiver	Ruffin argued the court’s inquiry was perfunctory, the form was ambiguous/blank about charges, and there was no advisement of maximum punishment	Reversed: waiver invalid — the record does not demonstrate Ruffin understood dangers/complexities or the penal consequences
Whether subsequent trial-court admonitions cured the master calendar deficiency	People argued later trial-department advisements and the signed form remedied any earlier shortfall	Ruffin argued later remarks were limited and did not cure absence of adequate advisals at the time waiver was taken	Held that later trial-department statements did not cure the inadequate master calendar advisement; the waiver remained invalid

Faretta v. California, 422 U.S. 806 (right to self-representation requires knowing and intelligent waiver)
Burgener v. California, 46 Cal.4th 231 (trial court must ensure record shows defendant understood dangers of self-representation)
Bush v. California, 7 Cal.App.5th 457 (entire record reviewed de novo to determine validity of Faretta waiver)
Blair v. California, 36 Cal.4th 686 (written and oral warnings may suffice where record shows defendant understood waiver)
Miranda v. California, 236 Cal.App.4th 978 (court should confirm defendant read and understood waiver form; stronger colloquy supported waiver)
Sullivan v. California, 151 Cal.App.4th 524 (discusses structural vs. harmless-error frameworks for inadequate Faretta advisals)
Marshall v. California, 15 Cal.4th 1 (courts must draw every inference against waiver; ambivalence supports denying pro per request)
Jackio v. California, 236 Cal.App.4th 445 (addresses whether court must advise defendant of maximum punishment)
Conners v. California, 168 Cal.App.4th 443 (written waiver plus extensive colloquy can satisfy Faretta requirements)
Fox v. California, 224 Cal.App.4th 424 (post-waiver explanations and inquiry into defendant’s background can support validity of waiver)