Kinard v. Commonwealth
In Kinard v. Commonwealth, 16 Va. App. 524, 527, 431 S.E.2d 84, 86 (1993) the Courthels that a defendant "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.'" . . .
"The primary inquiry . . . is not whether any particular ritual has been followed in advising the defendant of his rights and accepting his waiver, but simply whether the procedures followed were adequate to establish 'an intentional relinquishment of the right to counsel, known and understood by the accused. . . .'"
In Kinard, where the accused "moved to proceed pro se," 16 Va. App. at 526, 431 S.E.2d at 85, the Court found insufficient the trial judge's warnings that "you're making a big mistake" and that the accused would be "expected . . . to comport himself as any other lawyer." Id. at 527, 431 S.E.2d at 86.