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As a result, “it is within the trial court’s discretion to deny a defendant the right to continue his own defense if he acts in such a manner as to seriously disrupt the proceedings, either by refusing to exercise the decorum necessary to ensuring an orderly proceeding or by denying the court due respect.” ().

¶¶ 14-15 (2012) (rejecting argument that “serious obstructionist conduct” required to justify revocation of defendant’s self- representation and noting, “[a] defendant who proves himself incapable of abiding by the most basic rules of the court is not entitled to defend himself”) (internal quotation and citation omitted); (concluding revocation of defendant’s self- representation was not error because the court provided defendant “clear, unambiguous, and timely warnings that he would lose the ri

A defendant has a constitutional right to proceed without counsel, “but only so long as the defendant is able and willing to abide by the rules of procedure and courtroom protocol.” ¶ 8 (2012) ().

-11 (App. 1997) (addressing the sufficiency of the evidence to sustain the verdicts, even though defense counsel had waived the issue by failing to contest it at trial).

–223, ¶¶ 8, 15, –99 (2012)

¶33 We will review an ineffective assistance of counsel claim on direct appeal only if “we may clearly determine from the record that the ineffective assistance claim is meritless.” ().

4 STATE v. COTHAM Decision of the Court P.3d 831, 835 (2003) (citing cases), “but only so long as the defendant ‘is able and willing to abide by the rules of procedure and courtroom protocol,’” (citation omitted).

However, serious and obstructionist behavior “is [not] the only type of behavior that may warrant such a revocation.”

United States and Arizona Constitutions includes an accused’s right to proceed without counsel and represent himself,” ¶ 22, “but only so long as the defendant ‘is able and willing to abide by the rules of procedure and courtroom protocol.’” State v. Whalen, 192 Ariz. 103, 106, (quoting McKaskle v. Wiggins, 465 U.S. 168, 173 (1984)).

petent defendant cannot validly waive the right to counsel.” (citation omitted)); De Nistor, 143 Ariz. at 413 , 694 P.2d at 243 (affirming court’s refusal to allow defendant to waive counsel when there were several de *577 lays in proceedings and requests for new counsel; witnesses would be inconvenienced); Martin, 102 Ariz. at 146 , 426 P.2d at 643 (ongoing in-court misconduct); , (holding no error in revoking pro se right where defendant was warned continued behavior would result in loss of ri