State v. Bakalov
In State v. Bakalov, 1999 UT 45, 979 P.2d 799, the Court held that a defendant who refused to cooperate with his appointed counsel, instead insisting that the court appoint counsel from outside the jurisdiction, could not later argue that he was denied assistance of counsel when he elected to proceed pro se rather than accept previously appointed counsel.
The Court have said that forcing a defendant to choose between self-representation and incompetent counsel equates to a denial of the assistance of counsel. See id.
But requiring a defendant to "choose between waiver of counsel and another course of action as long as the choice presented to him is not constitutionally offensive" is perfectly permissible. Id.