Does a Defendant Have the Right to Defend Himself As Long As It Is Done Knowingly and Intelligently ?
In Faretta v. California, 422 U.S. 806, 45 L. Ed. 2d 562, 95 S. Ct. 2525 (1975), the Court held a defendant may waive the right to court-appointed counsel and choose to represent himself as long as the waiver is knowing and intelligent:
When an accused manages his own defense, he relinquishes, as a purely factual matter, many of the traditional benefits associated with the right to counsel.
For this reason, in order to represent himself, the accused must "knowingly and intelligently" forgo those relinquished benefits. Johnson v. Zerbst, 304 U.S.  at 464-465[, 58 S. Ct. 1019, 82 L. Ed 1461 (1938)]. Cf. Von Moltke v. Gillies, 332 U.S. 708, 723, 92 L. Ed. 309, 68 S. Ct. 316--724 (plurality opinion of Black, J.).
Although a defendant need not himself have the skill and experience of a lawyer in order to competently and intelligently to choose self-representation, he should be made aware of the dangers and disadvantages of self-representation, so that the record will establish that "he knows what he is doing and his choice is made with eyes open." Adams v. United States ex rel. McCann, 317 U.S.  at 279[, 63 S. Ct. 236, 87 L. Ed. 268 (1942)]. Faretta, 422 U.S. at 835.