Refusal to Undergo a Faretta Canvass as Waiver of the Right to Self‑Representation: Commentary on State v. Dist. Ct. (Kirk, Jr.)

I. Introduction

In State of Nevada v. Eighth Judicial District Court (Kirk, Jr.), 141 Nev., Advance Opinion 60, the Nevada Supreme Court confronted a recurring and difficult problem in criminal procedure: what should a trial court do when a defendant insists on representing himself but refuses to participate in the required Faretta canvass that safeguards his right to counsel?

The case arises from a prosecution of Lee Bryan Kirk, Jr. for a category C felony—carrying a concealed explosive substance, firearm, pneumatic gun, or other dangerous or deadly weapon. Although repeatedly expressing a desire to proceed pro se, Kirk simultaneously and adamantly refused to answer the court’s questions during multiple attempted Faretta canvasses. On the eve of trial, the district court, frustrated by a complete breakdown of the attorney-client relationship and by Kirk’s obstructive conduct, granted his counsel’s motion to withdraw and allowed Kirk to represent himself—without having ever obtained a valid waiver of counsel on the record.

The State petitioned the Nevada Supreme Court for an emergency writ of mandamus, arguing that the district court had manifestly abused its discretion by allowing self-representation without the constitutionally required showing that Kirk knowingly, intelligently, and voluntarily waived his right to counsel. The Supreme Court granted the petition, issued an emergency order before trial, and now, in this published opinion, explains its reasoning.

The central holding establishes an important new rule for Nevada:

When a defendant asserts the right to self-representation but refuses to participate in a Faretta canvass, that refusal constitutes a waiver of the right to self-representation itself. The trial court must deny self-representation and keep counsel appointed unless and until the defendant cooperates with the canvass and validly waives counsel.

This commentary analyzes the opinion’s background, the authorities it relies on, its legal reasoning, and its broader implications for Nevada criminal practice and the doctrine of self-representation.

II. Summary of the Opinion

A. Procedural and Factual Background

Kirk was indicted by a grand jury on a category C felony weapons charge. A public defender was appointed. At arraignment, Kirk:

Pleaded not guilty;
Invoked the 60-day trial rule; and
Stated that he wished to represent himself.

The district court properly set the matter for a Faretta canvass. At the first canvass hearing, however, Kirk refused to answer the court’s questions. Because it could not determine whether any waiver of counsel would be knowing and voluntary, the court:

Denied Kirk’s request to represent himself; and
Kept the public defender on the case, while advising Kirk that it would reconsider self-representation if he later agreed to submit to a canvass.

The attorney-client relationship then deteriorated. The public defender sought to withdraw, citing a complete breakdown. At the hearing on that motion, Kirk again insisted he wanted to represent himself, and again refused to cooperate with a Faretta canvass. The court:

Denied self-representation a second time due to the failed canvass;
Allowed the public defender to withdraw; and
Appointed conflict counsel.

Conflict counsel requested a competency evaluation. Initially, Kirk refused to speak to the evaluators, invoking the Fifth Amendment, but he eventually submitted to examination. He was found competent—able to understand the proceedings and to assist counsel.

Throughout, Kirk filed a “flurry” of pro se documents asserting that:

The court lacked jurisdiction;
He had a constitutional right to self-representation “without going through a test called a Faretta Hearing”;
He would “not take part” in any Faretta canvass, claiming it “violates [his] rights”;
Any appointed lawyer who believed they represented him was “fired”; and
He expected to “win on these grounds on appeals and in the upper courts.”

As trial approached, yet another appointed attorney moved to withdraw. During that hearing, Kirk again demanded to represent himself while again refusing a Faretta canvass. This time, the district court:

Granted counsel’s motion to withdraw; and
Allowed Kirk to represent himself, reasoning that his obstructive conduct amounted to a “forfeiture” of his right to counsel and made a canvass unnecessary.

The State then sought emergency mandamus relief in the Nevada Supreme Court, arguing that:

The right to self-representation is conditional, not absolute;
A valid, on-the-record waiver of counsel requires a proper canvass;
Kirk’s refusal to submit to a canvass precluded a finding of knowing and intelligent waiver; and
Allowing him to proceed pro se under these circumstances was a manifest abuse of discretion.

B. Holding

The Nevada Supreme Court:

Exercised its discretionary original jurisdiction to entertain the State’s mandamus petition in the interest of judicial economy, because the order was not independently appealable and allowing trial to proceed risked a void conviction and future retrial.
Held that a defendant’s refusal to participate in a Faretta canvass constitutes a waiver of the right to self-representation. A defendant may not demand self-representation on the one hand and then, on the other, refuse the procedural safeguard that alone makes a waiver of counsel valid.
Concluded that the district court “manifestly abused its discretion” by allowing Kirk to represent himself after he repeatedly thwarted the Faretta inquiry.
Directed the district court to reappoint counsel and to continue denying self-representation unless and until Kirk submits to a complete Faretta canvass and thereby validly waives his right to counsel.

The Court also clarifies that such a waiver of the self-representation right is not necessarily permanent; if a defendant later agrees to cooperate and “promises to conduct himself properly,” the court should revisit a renewed request for self-representation.

III. Precedents and Authorities Cited

A. Constitutional Framework

The Court grounds its analysis in the parallel guarantees of:

Sixth Amendment, U.S. Constitution – providing that the accused shall “have the Assistance of Counsel for his defence.”
Article 1, § 8(1) of the Nevada Constitution – similarly guaranteeing the right to counsel in criminal cases.

These provisions not only guarantee the right to be represented by counsel but also, under Faretta v. California, 422 U.S. 806 (1975), are understood to imply a corresponding right of self-representation. The Nevada Constitution is interpreted in lockstep with the federal right in this respect.

B. Faretta v. California and Its Legacy

Faretta held that a criminal defendant has a constitutional right to represent himself, but only if he:

Knowingly, intelligently, and voluntarily waives his right to counsel; and
Is made aware of the “dangers and disadvantages of self-representation.”

The Nevada Supreme Court repeatedly reaffirms that a Faretta-type canvass (referred to throughout the opinion simply as a “Faretta canvass”) is the mechanism by which Nevada courts ensure that any waiver of counsel meets this constitutional standard.

C. Nevada Authorities

1. Miles v. State, 137 Nev. 747, 500 P.3d 1263 (2021)

Miles is the Court’s primary recent decision on self-representation. It:

Describes the “tension inherent in the simultaneous guarantees” of the right to counsel and the right to self-representation.
Quotes the Sixth Circuit in Pryor to describe these as “two faces of the same coin,” where asserting one necessarily waives the other.
Emphasizes that improper handling of a Faretta canvass risks:
- Reversal for allowing self-representation without a valid waiver; or
- Reversal for denying self-representation when properly invoked.
Stresses that convictions after invalid waivers of counsel are per se invalid and not subject to harmless-error review.
Urges district courts to conduct a “thorough” and meaningful canvass, but clarifies that the canvass is not a “law school exam” that defendants must “pass.”

Kirk builds directly upon Miles by addressing a question that Miles left open: what happens when the defendant refuses to participate in the canvass at all?

2. Vanisi v. State, 117 Nev. 330, 22 P.3d 1164 (2001)

Vanisi supplies much of the doctrinal framework:

It holds that a defendant must satisfy the court that any waiver of counsel is knowing and voluntary.
It notes that a request for self-representation may be denied if:
- Untimely;
- Equivocal;
- Made solely for delay; or
- The defendant is disruptive.

In Kirk, the Court acknowledges these recognized grounds for denying self-representation and adds a new, specific one for Nevada: refusal to participate in a Faretta canvass.

3. Supreme Court Rule 253 (SCR 253)

SCR 253(1) requires Nevada district courts, when a defendant wishes to proceed without counsel, to conduct:

“a specific, penetrating and comprehensive inquiry of the defendant to determine whether the defendant understands the consequences of his or her decision to proceed without counsel.”

The rule codifies the expectation of a robust Faretta canvass and underscores that the inquiry must be substantive and searching. Kirk relies on SCR 253 as a baseline for what the trial court was required—but prevented—to do.

4. Writ Practice and Judicial Economy Cases

D.R. Horton, Inc. v. Eighth Judicial Dist. Ct., 123 Nev. 468, 168 P.3d 731 (2007) – discusses mandamus as a remedy for “manifest abuse of discretion” and clarifies that mandamus is discretionary and available when there is no “plain, speedy, and adequate remedy at law.”
Pan v. Eighth Judicial Dist. Ct., 120 Nev. 222, 88 P.3d 840 (2004) – reinforces that the petitioner bears the burden to show entitlement to extraordinary relief.
A.J. v. Eighth Judicial Dist. Ct., 133 Nev. 202, 394 P.3d 1209 (2017) – illustrates that the Court “routinely” exercises writ jurisdiction where important legal questions need clarification and intervention will promote judicial economy.

In Kirk, these authorities justify the Court’s decision to intervene pretrial. A conviction following an invalid waiver of counsel would be per se reversible, making a full trial, appeal, and inevitable retrial a foreseeable waste of judicial resources.

D. Federal Circuit and Sister-State Authorities

1. United States v. Pryor, 842 F.3d 441 (6th Cir. 2016)

Pryor is central to the Nevada Supreme Court’s reasoning. It:

Recognizes the trial court’s “dilemma” in balancing the right to counsel and the right to self-representation.
Explains that courts mitigate this dilemma by:
- Allowing defendants to indicate a desire to waive counsel; and
- Undertaking a thorough review of the disadvantages of self-representation.
Holds that when a defendant, “through his own actions,” prevents the court from determining whether his waiver is knowing or voluntary, he cannot later claim error in the court’s refusal to accept the waiver.
Concludes that a defendant’s “rejection of further inquiry into his waiver of counsel” and “nonanswers” may themselves constitute a waiver of the right to self-representation.

Kirk explicitly adopts this approach: a defendant cannot refuse to cooperate with the canvass and then demand the benefit of self-representation while preserving an appellate claim based on the very refusal.

2. People v. Lavadie, 489 P.3d 1208 (Colo. 2021)

The Colorado Supreme Court’s decision in Lavadie is closely analogous:

The defendant wanted to represent himself but repeatedly refused to answer the trial court’s questions under Colorado’s Arguello advisement (functionally equivalent to a Faretta canvass).
The trial court denied self-representation because it could not establish a knowing and intelligent waiver.
Colorado’s high court affirmed, emphasizing the distinction between a strong desire to proceed without a lawyer and a valid waiver of counsel.

Nevada endorses that distinction, citing Lavadie as supporting authority for the proposition that persistent noncooperation with a canvass justifies denial of self-representation.

3. Other Federal & State Decisions

The Court also cites a consistent line of federal appellate and state decisions:

United States v. Hausa, 922 F.3d 129 (2d Cir. 2019) – upholds denial of self-representation where the defendant “prevented the court from assessing his purported waiver” by refusing to answer questions about the risks of self-representation.
United States v. Krug, 822 F.3d 994 (8th Cir. 2016) – finds no error in denying self-representation when the defendant refused to answer the court’s questions, thereby making a knowing and voluntary waiver impossible to find.
Raulerson v. Wainwright, 732 F.2d 803 (11th Cir. 1984) – holds that a defendant who walked out of the courtroom during the Faretta canvass effectively waived his right to self-representation.
People v. Gregory, 81 N.Y.S.3d 472 (App. Div. 2018) – sustains denial of self-representation based on the defendant’s unwillingness to engage with the court or communicate effectively.
United States v. Washington, No. 21‑2740, 2023 WL 128928 (3d Cir. Jan. 9, 2023) – (cited by analogy) explains that a defendant cannot refuse to participate in a Faretta inquiry and later argue that the court erred by granting his request to proceed pro se in reliance on that very failure.

The opinion also notes cases where similar obstructive conduct justified revocation of previously granted pro se status:

United States v. Brunson, 482 F. App’x 811 (4th Cir. 2012); and
United States v. Brock, 159 F.3d 1077 (7th Cir. 1998), and the Supreme Court’s guidance in Illinois v. Allen, 397 U.S. 337 (1970) on dealing with obstreperous defendants.

Together, these authorities show a broad consensus: defendants may not weaponize the right of self-representation to disrupt proceedings or to set up reversible error by refusing to cooperatively undergo the waiver inquiry.

IV. The Court’s Legal Reasoning

A. Writ Jurisdiction and Standard of Review

The Nevada Supreme Court invokes its original jurisdiction under Article 6, § 4 of the Nevada Constitution to issue writs of mandamus. It reiterates:

Mandamus is available to correct a manifest abuse of discretion or an arbitrary or capricious exercise of discretion.
The writ is discretionary and appropriate only when there is no “plain, speedy, and adequate remedy at law.”

Allowing trial to proceed with Kirk representing himself—without a valid waiver of counsel—would almost certainly produce a per se invalid conviction. Because such an error is not subject to harmless-error analysis, reversal would be automatic. The Court therefore treats pretrial intervention as necessary to avoid wasteful duplication of proceedings and to clarify important law on self-representation.

B. The “Tension” Between Right to Counsel and Right to Self‑Representation

The Court, citing Miles and Pryor, stresses that:

The right to counsel and the right to represent oneself are “two faces of the same coin.”
Assertion of one necessarily entails waiver of the other.
This duality places trial courts in a “narrowest of channels” between:
- Risking reversal for denying a validly invoked right to self-representation; and
- Risking reversal for allowing self-representation without a valid waiver of counsel.

The Court’s solution is to emphasize the centrality and indispensability of the Faretta canvass as the mechanism for navigating this narrow channel.

C. The Necessity of a Knowing, Intelligent, and Voluntary Waiver

Building on Vanisi, SCR 253, and Miles, the Court reiterates that:

A defendant has a constitutional right to self-representation under both the U.S. and Nevada Constitutions.
However, self-representation is conditioned on a valid waiver of the right to counsel, which in turn requires:
- That the waiver be knowing, intelligent, and voluntary; and
- That the defendant be made aware of the “dangers and disadvantages” of self-representation.
A conviction after an invalid waiver of counsel is per se invalid and not subject to harmless-error analysis.

The Court underscores that a mere series of pro se filings or verbal statements asserting a desire to represent oneself shows, at best, a voluntary desire to forego counsel; it does not prove a knowing and intelligent waiver. The latter requires an informed understanding of the right being relinquished and the consequences of doing so—something that can only be adequately explored through a canvass.

D. Refusal to Participate in a Faretta Canvass as Waiver of Self‑Representation

The core doctrinal innovation of Kirk is the Court’s detailed treatment of how to handle a defendant’s outright refusal to cooperate with the canvass:

On one side, the defendant invokes the right to self-representation, sometimes insistently and repeatedly.
On the other side, he refuses to answer the very questions that would allow the court to verify a valid waiver of counsel.

Drawing on Pryor, Lavadie, Hausa, Krug, Raulerson, and Gregory, the Court concludes that:

“When a defendant asserts the right to self-representation but refuses to engage in a Faretta canvass, he waives the right to represent himself.”

The logic is straightforward:

The right to self-representation exists, but only upon a valid waiver of the right to counsel.
A valid waiver of counsel requires the court to be satisfied (through canvass) that the waiver is knowing, intelligent, and voluntary.
If the defendant, by his own conduct, prevents the court from making this determination—by refusing to answer or participate—then:
- The court cannot validly accept a waiver of counsel; and
- The condition precedent to exercising the right of self-representation never occurs.
Therefore, the defendant’s own refusal amounts to a waiver (or forfeiture) of the self-representation right, not of the right to counsel.

As the Court says in plain terms:

“Stated simply, a defendant cannot have it both ways.”

He cannot assert the right to represent himself while sabotaging the only process by which that right can be validly exercised.

E. Application to Kirk’s Conduct

Applied to Kirk, the Court notes:

He was repeatedly and clearly advised that the court would reconsider self-representation if he agreed to undergo a Faretta canvass.
On multiple occasions, he refused to answer questions during attempted canvasses.
He filed extensive pro se documents demonstrating a profound misunderstanding of the purpose of the canvass, wrongly believing it to be a “test” that infringed his rights.
A competency evaluation found him mentally competent, so his refusals were not attributable to incompetence.

The district court initially responded correctly—denying self-representation when it could not secure a valid waiver and keeping counsel appointed. But on the eve of trial, the court:

Shifted its approach, characterizing Kirk’s behavior as a forfeiture of the right to counsel and treating that forfeiture as eliminating the need for a Faretta canvass.
Permitted him to proceed pro se even though no valid waiver of counsel had ever been established.

The Supreme Court holds this to be a manifest abuse of discretion. The district court should have maintained its earlier, correct course: continue to deny self-representation unless and until Kirk submitted to a full canvass.

F. Not a Permanent Bar to Self‑Representation

The Court notes, citing Pryor and Illinois v. Allen, that this waiver of the right to self-representation is not necessarily permanent:

If a defendant later changes course, pledges to conduct himself properly, and is willing to engage in a proper canvass, the court should “reinvestigate the invocation.”
This leaves room for a defendant to regain the right to self-representation upon meaningful cooperation.

Thus, Kirk does not create an irrevocable penalty for an initial refusal; it creates a clear rule for what must occur at the point of refusal and how courts must act until the defendant is prepared to comply with the constitutional safeguards.

G. The Function and Value of the Faretta Canvass

The Court closes its doctrinal discussion by correcting Kirk’s misunderstanding of the Faretta canvass:

It is not a “test” designed to disqualify defendants from representing themselves.
Its purpose is to safeguard the accused’s constitutional right to counsel and the integrity of the justice system.
It may reveal to the defendant his own lack of understanding (for example, about the elements of the crime or the sentencing range), which itself demonstrates the risks of self-representation.
Armed with that information, a defendant may choose to continue with counsel rather than “make a fool of himself,” even if the law allows him to make an unwise choice.

The key policy message: the Faretta canvass is the gateway that ensures any decision to represent oneself is informed, not impulsive or manipulative.

V. Impact and Implications

A. Binding Rule for Nevada Trial Courts

State v. Dist. Ct. (Kirk, Jr.) sets out a clear, binding rule for Nevada:

If a defendant who wishes to represent himself refuses to participate in a Faretta canvass, the court must deny self-representation and keep counsel appointed. The refusal itself constitutes a waiver of the right to self-representation, not of the right to counsel.

This rule:

Prevents trial courts from feeling compelled to “give in” to obstructionist demands under the mistaken belief that the defendant has “forfeited” counsel.
Protects convictions from automatic reversal by ensuring that defendants do not go to trial pro se unless a valid waiver of counsel has been clearly established.
Provides a straightforward response when defendants refuse to engage with the canvass: maintain representation; do not allow pro se status.

B. Constraint on “Gamesmanship” and Disruption

The decision directly addresses what appears to be intentional “gaming” of the system by defendants who:

Insist on self-representation;
Refuse canvass questions;
Denounce the court’s jurisdiction; and
Openly predict success on appeal based on alleged procedural violations.

By characterizing refusal to canvass as waiver of self-representation, the Court removes the incentive for such tactics:

No defendant can create reversible error by sabotaging the canvass and then complaining that the court failed to secure a valid waiver.

pro se.

C. Reinforcing the Primacy of the Right to Counsel

Although the right to self-representation is “firmly embedded” in Nevada law, the opinion reinforces that:

The right to counsel is foundational and explicitly guaranteed.
The right to self-representation is an implication of that right, and necessarily subordinate in the sense that it can be exercised only by waiving the primary right.
Given the profound consequences of an invalid waiver, courts must err on the side of preserving counsel where the record is unclear or the defendant obstructs the canvass.

In this way, Kirk subtly rebalances the “tension” between the two rights, emphasizing that the justice system is not required to indulge self-defeating choices absent a solid record establishing that they are made with eyes open.

D. Clarifying Use of Mandamus in Criminal Procedure

The opinion further clarifies that:

Orders affecting self-representation and counsel are often not directly appealable pretrial.
However, where such orders present important, unsettled legal questions and threaten to invalidate a forthcoming trial, the State may appropriately seek mandamus relief.

This may guide future State petitions in circumstances where:

Trial courts grant pro se status without an adequate canvass; or
Refuse to allow self-representation despite a clear and valid Faretta waiver.

E. Interplay with Competency and Misconduct Doctrines

Kirk explicitly distinguishes between:

Competency – a defendant must be competent to stand trial and to waive counsel; here, Kirk was found competent.
Waiver vs. Forfeiture of Counsel – the district court tried to describe Kirk’s conduct as “forfeiture” of counsel, but the Supreme Court’s analysis clarifies that:
- Obstructive behavior may justify other sanctions (including potentially revoking pro se status or even proceeding without the defendant physically present in extreme cases);
- But here, the appropriate doctrinal response was to treat his refusal as a waiver of the right to self-representation, not as a basis to strip him of the right to counsel.

The decision suggests that Nevada courts must be cautious in invoking “forfeiture” of counsel; there is a clear preference for preserving representation where possible and focusing on conduct-based limitations (like revocation of pro se status or denial of self-representation) rather than total deprivation of counsel.

VI. Key Legal Concepts Explained

A. The Faretta Canvass

A “Faretta canvass” is a structured conversation on the record between the judge and a defendant who wishes to represent himself. The judge typically:

Explains the charges and potential penalties;
Describes the advantages of representation by trained counsel;
Warns about the technical rules of evidence and procedure;
Asks questions to confirm the defendant understands these points; and
Ensures that the decision is not the product of coercion, confusion, or misunderstanding.

The goal is not to quiz the defendant on the law but to make sure he is making an informed choice. The canvass protects:

The defendant’s right to counsel by preventing unknowing waivers; and
The validity of any resulting conviction.

B. Knowing, Intelligent, and Voluntary Waiver

A waiver of a constitutional right—like the right to counsel—must be:

Knowing – the defendant understands the nature of the right and the consequences of giving it up.
Intelligent – the decision is made with sufficient awareness of relevant facts and legal realities.
Voluntary – the decision is not coerced or forced, and is the product of the defendant’s own free will.

A defendant’s mere insistence that he wants to represent himself does not automatically satisfy these requirements. The canvass is how courts test and confirm them.

C. Waiver vs. Forfeiture vs. Revocation

Waiver – the intentional relinquishment of a known right (e.g., validly waiving counsel after a Faretta canvass).
Forfeiture – loss of a right because of one’s own serious misconduct, even without an express waiver (e.g., in some jurisdictions, egregious abuse of counsel can lead to “forfeiture” of the right to counsel).
Revocation – withdrawal of a previously granted procedural position (e.g., revoking pro se status when a defendant becomes disruptive).

In Kirk, the Supreme Court clarifies that:

The district court erred in treating Kirk’s behavior as a “forfeiture” of counsel that eliminated the need for a canvass.
The correct characterization is that his refusal to participate in a canvass waived the right to self-representation, meaning the court was obliged to keep counsel in place.

D. Per Se Reversible Error

Some errors are so fundamental that, if they occur, the resulting conviction must be reversed automatically, without asking whether the error made a difference. An invalid waiver of counsel is one such error:

If the record does not show a valid, knowing, intelligent, and voluntary waiver;
Then any conviction obtained while the defendant was unrepresented is per se invalid.

This is why the Nevada Supreme Court intervened via mandamus pretrial in Kirk: to prevent an inevitably void conviction and the need for a second trial.

E. Mandamus

A writ of mandamus is an extraordinary order from a higher court directing a lower court or official to perform a required duty. In Nevada:

The Supreme Court may issue mandamus to control a manifest abuse of discretion.
Mandamus is used sparingly, typically where:
- There is no adequate remedy by appeal; and
- An important legal question needs clarification.

In Kirk, the Supreme Court used mandamus to:

Prevent an unconstitutional trial from going forward;
Clarify the law concerning refusal of Faretta canvasses; and
Promote judicial economy by avoiding a futile trial and inevitable retrial.

VII. Conclusion

State v. Dist. Ct. (Kirk, Jr.) is a significant refinement of Nevada law on the right of self-representation. Building on Faretta, Vanisi, and Miles, and aligning Nevada with a strong national consensus, the Supreme Court holds that:

A defendant has a constitutional right to represent himself, but only after validly waiving the right to counsel.
A valid waiver of counsel requires a thorough, on-the-record Faretta canvass that establishes the waiver as knowing, intelligent, and voluntary.
When a defendant refuses to participate in that canvass, he thereby waives the right to self-representation itself.
Trial courts must deny self-representation and keep counsel appointed unless and until the defendant cooperates with a full canvass.
Yielding to obstructionist tactics by allowing uncounselled trials without a valid waiver is a manifest abuse of discretion, subject to correction via mandamus.

The opinion firmly rejects the notion that a defendant can “have it both ways”: demanding self-representation while sabotaging the conditions that make self-representation constitutionally lawful. It instructs trial courts not to succumb to frustration or manipulation but to hold to the constitutional line: no self-representation without a valid, informed waiver of counsel.

In doing so, Kirk both protects defendants from the dire consequences of ill-informed choices and safeguards the criminal justice system from avoidable reversals and retrials. It will stand as the leading Nevada authority on what happens when defendants refuse a Faretta canvass, and it provides clear, practical guidance to judges, prosecutors, and defense counsel alike.

Note: This commentary is an analytical summary of the opinion and does not constitute legal advice.