In Fowler v. Collins (6th Cir. 2001) 253 F.3d 244, defendant faced a 46-count indictment. The court did not advise him of any of the dangers or risks of self-representation and encouraged him to waive both reading of the indictment and an explanation of his constitutional and statutory rights. (Id. at p. 247.) The Sixth Circuit found the cursory investigation of defendant's waiver -- the court asked only once if defendant would represent himself -- did not meet Faretta standards. (Id. at p. 250.)