People v. Woodson

In denying Defendant's repeated requests to proceed pre se, the trial court focused exclusively, and erroneously, on the fact that Defendant did not have sufficient legal knowledge and expertise to represent himself. Proper standard for deciding request to proceed pro se is whether Defendant has the ability to making a knowing and intelligent waiver of his right to counsel, not an inquiry into his ability to appropriately defend himself at trial. (APPLETON and McCULLOUGH, concurring.)