On October 5, 1970, in a Los Angeles courtroom, a defendant who had just been refused permission to cross-examine a detective came out of his chair with a pencil in his hand and went toward the judge. Charles Manson, shouting that someone should cut off the judge’s head, got as far as the bench before bailiffs wrestled him down. The women on trial with him began to chant. The judge was Charles Older, fifty-two, a decorated fighter pilot in the Second World War who had been on the bench three years. What he and other judges did in the face of such moments, in California, Pennsylvania, Florida, Wisconsin, Texas and Germany, followed a few familiar lines. A judge removed a disruptive defendant. In one instance a judge silenced one with a gag. A judge declined to let another dismiss his lawyers and run his own trial. And a higher court, when asked, generally said the judge had acted within his discretion.
The rulings that followed are as telling as the moments themselves. In one trial a defendant’s courtroom behavior cost him the right to defend himself. In another a reporter, not a defendant, was thrown out. In a third a sentencing hearing proceeded with the defendant gagged. Relatives of the dead shouted, wept and lunged. Eight cases follow, from the moment of disruption to the appellate ruling where there was one.
Manson asked to act as his own lawyer, saying that "there is no person in the world who could represent" him, and Judge William Keene, after a competency review, let him. He used the privilege to demand copies of every document in the case, freedom to travel and the addresses of every prosecution witness. In March 1970, when he asked that the prosecutors be jailed under the same conditions as he was, Keene revoked it, and Manson shouted, "There is no God in this courtroom!" He went through two appointed lawyers, Charles Hollopeter and then Ronald Hughes, filed an affidavit of prejudice against Keene, and drew Older. Two weeks before trial he asked Older to replace Hughes with Irving Kanarek, a lawyer known for burying trials in objections. Manson himself said Kanarek might be "the worst attorney I could take." Older, finding no legal ground to refuse, agreed.
Kanarek objected nine times during the prosecution’s opening statement and, by the press’s count, more than two hundred times in the first days before reporters stopped counting. He cross-examined the main prosecution witness, Linda Kasabian, for seven days. Older held him in contempt four times during the trial and twice sent him to the county jail overnight.
The case then took a turn that no judge can script. In early August 1970, while Kasabian was still under cross-examination, President Richard Nixon told reporters in Denver that Manson was "guilty, directly or indirectly of eight murders." The White House said it had not meant to prejudice the trial. The next day Manson stood and held up a newspaper headline, "Manson Guilty, Nixon Declares," so that the jurors could see it. Older questioned each juror, was satisfied they could remain fair, denied a mistrial and sent Daye Shinn, a lawyer who had left the paper within Manson’s reach, to jail for three nights.
The October 5 outburst came after weeks of this. The defendants were convicted in January 1971 of the Tate-LaBianca murders, seven counts for Manson alone, and sentenced to death. When the Court of Appeal reviewed the record in 1976, in People v. Manson, 61 Cal.App.3d 102, it affirmed the judgments against Manson, Susan Atkins and Patricia Krenwinkel. It rejected his complaints about the grand jury, the jury panel and the photographs, and held that the marks the defendants had put on their own foreheads were harm they had done themselves. It noted that in 18 days of examination Kasabian "testified clearly and comprehensibly."
A second trial followed in 1971, for the murders of Gary Hinman and Donald Shea. Manson was tried alone. Jury selection took twenty-four days and the trial forty-three; the transcript runs to 11,118 pages. He asked to represent himself again, and this time the judge refused: "You don’t have the capacity to waive counsel." He was removed from the courtroom repeatedly and went on shouting through the open door of the holding cell until the door was closed. On July 14, with the jury out of the room, he announced a plea of guilty to one of the murders; the court did not accept it, because his lawyer would not join the plea. On August 10, while a witness was on the stand and the lawyers were at the bench, he made a remark to a sergeant at the counsel table that another officer overheard, and the trial court ruled the statement voluntary. During a two-week recess a group of his followers allegedly robbed a gun store in Hawthorne, planning to take the judge and the prosecutor hostage to free him. Seven jurors or alternates said they had seen or heard something about it.
The jury began deliberating on October 21 and returned its verdicts on November 2, 1971: guilty of the murders of Hinman and Shea and of conspiracy, with life sentences. On appeal in 1977, in People v. Manson, 71 Cal.App.3d 1, the court affirmed, observing that "neither case was a close case." On his claim that he had been wrongly denied the right to defend himself, it noted that he had been disruptive enough to forfeit it, and that, left to himself, he would simply have pleaded guilty.
His death sentences ended differently. The sentence was vacated after the California Supreme Court’s 1972 decision in People v. Anderson and formally modified to life on February 2, 1977. He was denied parole twelve times and died at a Kern County hospital on November 19, 2017, aged 83.
Manson’s trials set the pattern in which a defendant forces a judge to choose between the dignity of the courtroom and the defendant’s own rights, and the appellate courts afterward back the judge. A related episode from the same case: William Farr, a Los Angeles reporter who refused to name the lawyers who had leaked a co-defendant’s jailhouse story to him, spent forty-six days in jail for contempt before an appeals court freed him in 1976. California later widened its shield law to cover former reporters.
Charles Cullen, a registered nurse, pleaded guilty between 2004 and 2006 to murdering 29 patients at hospitals in New Jersey and Pennsylvania and to six attempted murders, in exchange for avoiding the death penalty in any of the seven counties involved. He told detectives the true number of patients he had killed was 30 to 40.
On March 2, 2006, in Somerville, New Jersey, Superior Court Judge Paul W. Armstrong sentenced him to 11 consecutive life terms. Relatives of the dead confronted him, the Associated Press reported. Eight days later, on March 10, he came before President Judge William Platt in the Lehigh County Court of Common Pleas in Allentown, where he faced sentencing for six murders and three attempted murders, and a separate sentence for one murder in Northampton County.
Cullen had a grievance. Platt had made remarks to a newspaper about compelling him to attend the sentencing, and Cullen objected. The hearing began with him repeating a single sentence, "Your honor, you need to step down," hundreds of times over about 30 minutes. The judge had him gagged with a cloth and duct tape. He kept on, and the hearing went ahead. Platt sentenced him to six more life terms, bringing the total to 18, along with life without parole for the Northampton County murder.
The relatives who spoke did not wait for quiet. "We think you are a total waste of human flesh," said Walter Henne, the son-in-law of Irene Krapf, a patient Cullen had killed. Julie Sanders, a friend of another victim, John Gallagher, said Cullen had meant to show disrespect to everyone in the courtroom. The Associated Press headlined its account of the hearing that the court had gagged the killer nurse during sentencing.
The gag came at a sentencing, not a trial, after pleas that had already spared him the death penalty. Cullen is held at New Jersey State Prison in Trenton and was serving his life terms as of a December 2025 report.
Court proceedings give relatives of the dead a place to speak, and the rules for what they may do there are looser than anyone expects. Two sentencings in the early 1990s show the range.
Danny Rolling pleaded guilty on February 15, 1994, to five counts of first-degree murder, with other charges, for killings in Gainesville, Florida, over four days in August 1990. The victims were four University of Florida students and one student at Santa Fe Community College. On March 24, 1994, the penalty-phase jury recommended death on each murder count by a vote of 12 to 0. On April 20, 1994, Circuit Judge Stan R. Morris imposed five death sentences. Rolling said nothing as they were read. Ricky Paules, the mother of Tracy Paules, called out "Yes!" As Rolling was led out, Mario Taboada, the brother of Manuel Taboada, shouted that the children’s names would be remembered over the killer’s, and he was removed from the courtroom. Sonja Larson’s brother confronted Sondra London, who had published the defendant’s writings, in the courtroom and warned her not to make money from his sister’s death; she said she had been threatened.
Morris’s handling of a grieving relative differed from the way Platt handled Cullen. Taboada was taken out and the sentencing went on. Rolling’s death sentences were affirmed by the Florida Supreme Court on March 20, 1997, and he was executed at Florida State Prison on October 25, 2006.
In Milwaukee in February 1992, a jury rejected Jeffrey Dahmer’s insanity defense on February 15. He had pleaded guilty but insane to fifteen counts of first-degree intentional homicide. The sentencing came two days later, on Monday, February 17. Judge Gram allowed relatives to speak, and most spoke calmly, one at a time. "Jeffrey Dahmer has erased a million future memories for me of my brother," said J.W. Smith, Eddie Smith’s brother, who also read a statement from their mother. Ernest Miller’s uncle, Stanley Miller, asked him: "Did you ever think this was someone’s son?" Inez Thomas told him he had taken away a two-year-old child’s father. Dorothy Straughter told him he had taken her son. Shirley Hughes read a poem a friend had written in her son’s voice.
Then Rita Isbell, Errol Lindsey’s sister, came forward shouting, called him Satan, screamed that she hated him and lunged toward him before deputies led her away. The proceeding went on.
Dahmer then spoke for the first time. "I take all the blame for what I did," he said. He said he had never wanted freedom and had wanted death for himself, that he had hated no one, and that he had "tried and failed, and created a holocaust." Judge Gram sentenced him to fifteen consecutive life terms. Wisconsin had no death penalty. Boyle, his lawyer, said there would be no appeal. Dahmer pleaded guilty to a sixteenth killing in Ohio in May 1992 and received a sixteenth life term. He was killed by a fellow inmate at Columbia Correctional Institution on November 28, 1994, aged 34.
Douglas Daniel Clark, a Burbank steam engineer, was convicted of the murders of six young women in Los Angeles County in the summer of 1980, after his girlfriend Carol Bundy telephoned police, confessed to a separate killing and named him. What matters here is what the trial judge did when the relationship between Clark and his appointed lawyer, Keith, collapsed in open court, and what the California Supreme Court said about it ten years later.
On July 26, 1982, Clark tried to dismiss Keith while keeping a second lawyer, Watson. On August 13 he formally asked to represent himself, and on August 20 the court denied the request as untimely. On August 27 Keith tried to enter a plea of not guilty by reason of insanity without Clark’s consent; the court refused to accept it, so no insanity plea was ever entered. Jury selection began on September 7, 1982. On September 20 Clark was removed from the courtroom after complaining about Keith.
He was convicted on six counts of first-degree murder with multiple-murder special circumstances and of mutilating a body, and on March 16, 1983, he was sentenced to six consecutive death terms. He was received on death row on March 24, 1983.
In People v. Clark, 3 Cal.4th 41, decided July 30, 1992, the California Supreme Court devoted much of its opinion to his fight over who would conduct his defense. It held that his July 1982 attempt to dismiss Keith was not a clear request to represent himself, that the trial judge acted within its discretion in denying the August 1982 request as untimely, and that his complaints about his lawyers did not require new counsel. It identified no error in the judge’s refusal to give him advisory counsel or a law clerk, whose help it called "merely convenient" rather than "reasonably necessary."
On the episode in which Clark announced that he would stand mute, the court read his announcement as part of a deliberate pattern of manipulation rather than a sincere choice to present no defense, and it quoted the United States Supreme Court’s warning that the right to represent oneself "is not a license to abuse the dignity of the courtroom." A dispassionate reading of the record, the majority wrote, showed that Clark "was playing games with the court." It concluded that his December 1982 conduct was meant to disrupt and delay the trial. It also noted a letter of his implying that he was trying to plant reversible error in the record, and it held that he had not succeeded.
Two justices dissented on opposite grounds. Justice Kennard argued that the trial court erred in not letting Clark represent himself by standing mute. Justice Mosk identified error in the grant of self-representation itself. The court reversed the attempted murder and mayhem convictions from a separate case and set aside all but one special-circumstance finding, but affirmed the murder convictions and the death judgment.
The Ninth Circuit rejected his federal habeas appeal on October 10, 2023. Clark died of natural causes at an outside medical facility on October 11, 2023, aged 75, while on condemned status at San Quentin.
David Leonard Wood has been under a sentence of death in Texas since 1993 over the deaths of six girls and young women from El Paso in 1987. The case was moved from El Paso to Dallas because of publicity, and a Dallas jury convicted him of capital murder in 1992, under the provision of the Texas Penal Code covering the murder of more than one person during the same scheme or course of conduct.
His trial lawyer, Quijano, later described Wood as an extremely difficult client. At one point during the prosecution’s case, after an outburst, Wood was removed from the courtroom. He has long described himself as a scapegoat. The defense put on evidence about his intellectual functioning, including testimony that his IQ was below 70 and an expert from San Francisco, Quijano told KVIA in 2009. "We put all the evidence before the jury," he said.
The Fifth Circuit gives the date of the conviction as November 30, 1992; San Angelo LIVE! gives November 10 for the verdict and November 30 for the death sentence. He was received on death row on January 14, 1993. His direct appeal was affirmed on December 13, 1995; state habeas relief was denied in 2001 and federal habeas relief in 2006, and the Supreme Court denied certiorari on April 14, 2008.
Wood’s removal from his own trial is not reported to have become a ground of appeal. What became of the case came later and from a different direction. An execution set for August 20, 2009, was stayed on August 19 for an intellectual-disability claim, which was denied in 2014 and again in 2018. A request for DNA testing was denied on March 3, 2022, and that denial was affirmed on May 22, 2024. An execution set for March 13, 2025, was stayed two days earlier, on March 11. The Court of Criminal Appeals sent the case back to the trial court on July 30, 2025, and on September 4, 2026, a visiting judge, Dick Alcalá, granted new DNA testing. Wood denies all of the killings. As of March 12, 2026, he was on the Texas death row list.
Charles Chitat Ng was convicted in February 1999 of murdering 11 people in the Sierra Nevada foothills in 1984 and 1985. He was arrested in Calgary on July 6, 1985, after Leonard Lake’s arrest in California, and spent six years fighting extradition.
At a preliminary hearing in Calaveras County, Ng appeared shackled inside a steel security cage, the journalist Debra J. Saunders reported. His lawyers argued that coverage of the case made a fair trial in Calaveras County impossible. Great American Trials says a poll showed that 98 percent of local residents knew of the case and that most thought he was guilty. On April 8, 1994, the case was moved to Orange County, and the parties first appeared there on September 30, 1994. By then, Saunders wrote, Ng had gone through five judges, and the state supreme court had ruled on questions about his representation eight times.
The court appointed the Orange County Public Defender, William G. Kelley, in 1994. In 1995 Judge Robert R. Fitzgerald, the third judge removed from the case, was taken off it after Ng reversed course about dismissing Kelley; an appeals court restored Kelley and removed Fitzgerald. A trial date of September 6, 1996, came and went. In 1998, with trial set for September 1 before Judge John J. Ryan, Ng moved to represent himself. A motion made on March 31, 1998, was denied on April 20, after a hearing at which the court ruled him competent but held that he did not sincerely want to represent himself and was trying to obstruct the case. A second motion, on May 8, was denied for the same reason. A third, on May 15, 1998, was granted, with the public defender as standby and advisory counsel.
The arrangement did not last. In August 1998 Ng asked for a six-month continuance and for a new competency hearing, saying he had slept poorly and felt tired and confused. Saunders reported that he cited headaches from new glasses, which affidavits from sheriff’s deputies disputed, and that he also wanted the case moved to San Francisco and more time for DNA tests. The court saw nothing wrong with his mental ability, granted only a two-week continuance, and revoked his self-representation, ruling that he was using it to delay and disrupt the trial. Kelley was again his lawyer.
The California Supreme Court reviewed the ruling in People v. Ng, decided July 28, 2022, in an opinion by Justice Groban that ran to 181 pages. No justice dissented. "We affirm the judgment in its entirety," the court wrote. It held that the trial court had not abused its discretion in ending Ng’s self-representation, citing substantial evidence that he had used it to delay the trial, and it pointed to the 37 Marsden motions, the formal requests to replace his lawyer, and to a statement he made in jail urging another inmate to file Marsden motions to restart his case. It upheld the denial of his 31st Marsden motion, filed the day after jury selection began, ruling that he was trying to manufacture a conflict with Kelley. Among its remaining holdings, the court identified no due process violation in the competency proceedings or in the physical restraints used on him, and no reversible error in the venue proceedings.
The jury convicted him on 11 counts on February 24, 1999, and did not reach a verdict on a twelfth, which the judge dropped. He was sentenced to death on June 30, 1999.
Ng’s case is a study in a different kind of disruption: not shouting, but motions. Thirty-seven requests for a new lawyer, three requests for self-representation, a continuance asked for partly on the strength of new glasses. The courts treated the sum of it as an effort to delay.
Fritz Haarmann was arrested at Hanover’s main railway station on June 22, 1924. He was tried before the Schwurgericht at the Landgericht Hannover from December 4 to 19, 1924, over 14 hearing days, on 27 counts of murder, together with Hans Grans, who was tried for incitement and aiding. On December 19 he was convicted of 24 murders of boys and young men and acquitted on three counts, and sentenced to death 24 times. He accepted the verdict and was beheaded by guillotine in the prison yard of the Landgericht Hannover at 6 a.m. on April 15, 1925. Grans was sentenced to death; after a retrial in 1926 he received 12 years' penitentiary for aiding two murders.
In Hanover the person removed from the courtroom was not the defendant. Theodor Lessing was a Jewish philosopher and lecturer at the Technische Hochschule Hannover, a pacifist and a well-known political commentator. He attended the trial as a press representative and wrote critically about it, especially about the police, whose use of Haarmann as an informer he made public, and about the court’s refusal to look at wider causes.
By Lessing’s own account, on the eleventh day of the trial the expert witnesses refused to present their opinions while he was in the room, the prosecution complained about his reports, and the defense took offense. The presiding judge told him he had been admitted as a reporter, not as a writer, and he was removed from the courtroom and barred from further coverage. The taz, writing in 1992, also dates his expulsion to the eleventh day.
He turned his notes into a book, Haarmann: Die Geschichte eines Werwolfs, dated January and February 1925 and published that year in Berlin by Die Schmiede. He called the verdict unsatisfying and said the authorities had avoided showing their own share of the blame. He proposed a public ceremony for the victims and a memorial stone with the inscription "Unser aller Schuld!" ("The guilt of us all!"). The Lower Saxony State Archive describes the book as a serious work of contemporary history.
Soon afterward Lessing was receiving hate mail and death threats. Nationalist and antisemitic students formed a committee against him, disrupted his lectures and called for his dismissal; some called for his death. About 1,500 corps students threatened to move to the technical university in Braunschweig, and the lord mayor of Hanover also demanded his removal. On May 14, 1925, a student assembly, backed by the rector and the university senate, asked the Prussian education minister to dismiss him. The minister, Carl Heinrich Becker, partly gave way: Lessing lost his teaching duties and was given a poorly paid research post instead.
On March 1, 1933, after the Nazis came to power, Lessing and his wife Ada fled to Czechoslovakia. His books were among those burned in Hanover in May 1933. On the evening of August 30, 1933, Sudeten German National Socialists killed him in Marienbad; he died in the hospital in the early hours of the next day. He is remembered as the first political murder victim of the Nazis outside Germany. Hanover has since honored him with a plaque and memorial stones for him and his wife.
The removals, the gag and the cage were not all the same kind of act, and the courts treated them differently.
Removal of a defendant appears in four of these cases: Manson in 1971, Clark in 1982, Wood in 1992 and, in the sense of a relative taken out of the room, Mario Taboada in 1994. Manson’s and Clark’s removals figure in appellate opinions, and both courts used the disruption to explain why self-representation had been denied or lost. A court that had watched a defendant’s behavior would not, the reasoning ran, rescue him from a consequence he had invited. Wood’s removal is reported only in his lawyer’s account.
The gag, in Cullen’s case, is not reported to have drawn an appellate ruling. The steel security cage and the physical restraints in Ng’s case did: the California Supreme Court, in 2022, identified no due process violation in the restraints used on him.
On self-representation the trial courts were consistent and the appellate judges, in one case, divided. Manson was allowed to defend himself in 1970 and lost the privilege within weeks; in 1971 he was refused outright. Clark was refused as untimely, and the California Supreme Court split three ways on whether the stand-mute episode should have been honored. Ng won the privilege on the third try and lost it within months. In each case the judge’s reasons were close to the same: the request was a device for delay.
Lessing’s removal is the outlier. He was not a party, and no court is reported to have reviewed the decision. The consequences ran through a university, a ministry and a political movement, and ended in Marienbad in 1933.
Families fared differently from defendants. Relatives who shouted, called out "Yes!" or lunged were mostly allowed to finish. Mario Taboada was removed. Rita Isbell was led away by deputies and the sentencing went on.
• 1924, June 22: Fritz Haarmann arrested at the main railway station in Hanover.
• 1924, December 4 to 19: Haarmann and Hans Grans tried in Hanover; Theodor Lessing removed on the eleventh day; Haarmann sentenced to death December 19.
• 1925, April 15: Haarmann beheaded in Hanover.
• 1925, May 14: student assembly asks the Prussian education minister to dismiss Lessing.
• 1933, August 30: Lessing attacked in Marienbad; dies the next day.
• 1970, March: Judge Keene revokes Charles Manson’s right to represent himself.
• 1970, August: President Nixon’s remark; Manson holds up a newspaper headline for the jurors.
• 1970, October 5: Manson lunges toward the bench; January 1971, convictions and death sentences.
• 1971, November 2: Manson’s second jury returns verdicts; life sentences.
• 1976, August 13: Court of Appeal affirms the Tate-LaBianca judgments against Manson, Atkins and Krenwinkel.
• 1977, June 23: Court of Appeal affirms the second Manson judgment.
• 1982, August to September: Douglas Clark’s request to represent himself denied; September 20, removed from the courtroom.
• 1983, March 16: Clark sentenced to six consecutive death terms.
• 1992, February 15 to 17: Jeffrey Dahmer’s jury rules him sane; sentencing and Rita Isbell’s outburst on February 17.
• 1992, July 30: California Supreme Court decides People v. Clark.
• 1992, November: David Leonard Wood convicted of capital murder in Dallas.
• 1994, April 20: Danny Rolling sentenced; Mario Taboada removed from the courtroom.
• 1998, May 15: Charles Ng granted self-representation; revoked in August.
• 1999, February 24: Ng convicted of 11 murders; sentenced to death June 30.
• 2006, March 2 and 10: Charles Cullen sentenced in Somerville and, gagged, in Allentown.
• 2022, July 28: California Supreme Court affirms Ng’s judgment.
• 2023, October 10 and 11: Ninth Circuit rejects Clark’s appeal; he dies.
• 2026, September 4: new DNA testing granted in Wood’s case.