In Blankenship v. State, 673 S.W.2d 578 (Tex. Crim. App. 1984), the defendant made an unequivocal request for self-representation: "I would like to pro se my own case." Id. at 580. The trial court inquired about the defendant's formal education and knowledge of the legal system. See id. at 580-82. Concluding that the defendant was unqualified to represent himself, the trial court made an express ruling: "I overrule you at this time. You will be represented by counsel in this case. That is all." Id. at 582. The Court of Criminal Appeals reversed, holding that the right to self-representation may not be denied merely because a defendant is unqualified to represent himself or lacks sufficient legal skills. Id. at 584.