PEOPLE v. ANDERSON

The court improperly denied defendant's request to proceed pro se when, during the court's inquiry, defendant revealed that he had problems with memory. As the People concede, the court's conclusion that defendant did not possess sufficient memory for self-representation was not a proper basis to deny the request ( see People v Reason, 37 NY2d 351). Contrary to the People's argument, defendant made a clear and unequivocal request to represent himself. He clearly differentiated that request from his prior request for new counsel, which the court had already denied ( compare People v Gillian, 8 NY3d 85). We have considered and rejected the People's remaining arguments.