People v. Washington

Court erred in finding Defendant unfit to stand trial. Where a trial court finds bona fide doubt exists as to a defendant's fitness to stand trial, the defendant loses ability to knowingly and intelligently waive right to counsel. To allow the defendant to proceed pro se is thus a violation of 6th amendment right to counsel. Once bona fide doubt is established, court is required, even over defendant's objection, to appoint counsel to represent defendant until defendant regains fitness to stand trial. (STEIGMANN and APPLETON, concurring.)