The California Supreme Court affirmed a judgment of conviction and penalty. The court held that a capital defendant who elected to represent himself had no statutory or state or federal constitutional right to the appointment of co-counsel.

In 1988, Charles Moore was convicted and sentenced to death for the 1977 robbery and murders of Robert and Marie Crumb. That judgment was vacated in federal habeas corpus proceedings based on the trial court’s violation of Moore’s right to represent himself.