In McKaskle v. Wiggins (1984) 465 U.S. 168, defendant's motion to proceed pro se was granted, but the court also appointed standby counsel. Both before and during trial, defendant frequently changed his mind about standby counsel's participation, sometimes objecting to that participation, but sometimes soliciting counsel's help. After his conviction, defendant urged that standby counsel's conduct had deprived him of his Faretta right to present his own defense. Rejecting that argument, the court reasoned in part, "A defendant can waive his Faretta rights..... Once a pro se defendant invites or agrees to any substantial participation by counsel, subsequent appearances by counsel must be presumed to be with the defendant's acquiescence, at least until the defendant expressly and unambiguously renews his request that standby counsel be silenced." ( Id. at pp. 182-183.) The United States Supreme Court addressed whether a defendant's right to self-representation had been violated by the participation of standby counsel, who were present at trial over the defendant's objection. The defendant in that case, at times, requested that counsel not be allowed to interfere with his presentations in court. Nonetheless, outside the presence of the jury, standby counsel explained their views, including disagreement with the defendant, to the trial court, made motions, proposed strategies on the record, and suggested questions for the defendant to ask. When the defendant complained on appeal that standby counsel's participation had impaired his right to represent himself, the reviewing court concluded: "No absolute bar on standby counsel's unsolicited participation is appropriate or was intended. The right to appear pro per exists to affirm the dignity and autonomy of the accused and to allow the presentation of what may, at least occasionally, be the accused's best possible defense. Both of these objectives can be achieved without categorically silencing standby counsel." (McKaskle, supra, 465 U.S. at pp. 170, 172-173, 176-177, 180.) The court imposed limits, however: "First, the pro per defendant is entitled to preserve actual control over the case he chooses to present to the jury. This is the core of the Faretta right. If standby counsel's participation over the defendant's objection effectively allows counsel to make or substantially interfere with any significant tactical decisions, or to control the questioning of witnesses, or to speak instead of the defendant on any matter of importance, the Faretta right is eroded.Second, participation by standby counsel without the defendant's consent should not be allowed to destroy the jury's perception that the defendant is representing himself." (McKaskle, supra, 465 U.S. at p. 178.) The court further stated: "Faretta rights are adequately vindicated in proceedings outside the presence of the jury if the pro per defendant is allowed to address the court freely on his own behalf and if disagreements between counsel and the pro per defendant are resolved in the defendant's favor whenever the matter is one that would normally be left to the discretion of counsel." (Id. at p. 179.) The Supreme Court concluded that standby counsel's participation outside the presence of the jury did not violate these limits because the defendant was given ample opportunity to present his own views and all conflicts were resolved in his favor. (Id. at p. 181.)