Hybrid representation is where the defendant serves as co-counsel with an attorney. The defendant does not have a constitutional right to hybrid representation. It is within the trial court's discretion to grant the defendant's request for hybrid representation. Hybrid representation may be disruptive to the judicial process when the defendant is asking questions and then the attorney asks questions. Trial judges may steer clear of permitting hybrid representation during a trial court proceeding because of the likelihood that such representation will not run smoothly.

Standby Attorney

The trial court judge appoints the standby attorney. The standby attorney plays a different role from the attorney representing the defendant in a hybrid situation. The standby attorney is not an active participant in the defendant's trial. The trial court judge may appoint the standby attorney to ensure that the defendant complies with court rules and procedures. The standby attorney may be appointed even over the defendant's objection. The role of the standby attorney encompasses:

• Assisting the defendant with courtroom procedures.
  
• Assisting the defendant with introducing evidence and testimony.
  
• Not directly participate in the trial court proceedings.
  
• Not undermining the appearance of the defendant's self-representation.
  
• Not interfering with the defendant's trial plan.
  
• Permitting the defendant to control the organization and content of his defense.

The defendant may not raise the issue that his standby attorney was ineffective on appeal because the role of the standby attorney is merely to assist the defendant and not to act as defendant's attorney or co-counsel. Typically, the role of the standby attorney during the defendant's trial will not undermine the defendant's right to self-representation as afforded by the Sixth Amendment of the United States Constitution.

Pro Se Representation of Another Defendant

A pro se appearance by definition means representation of oneself; therefore the defendant may not be represented by someone other than an attorney during trial or any other adversarial proceedings.

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