Is a pro se civil litigant's right of self-representation in state court protected as a fundamental federal constitutional right subject to the strict scrutiny test under the United States First Amendment (Free Speech, Free Exercise, Petition Clauses) as incorporated by the Fourteenth Amendment?

QUESTIONS PRESENTED In Faretta v. California, 422 U.S. 806, 829-32, 830 n.39, 833-34, 834 n.46 (1975), this Court held that state ; courts may not compel pro se litigants in criminal , cases to use an attorney (unless the pro se litigant’s conduct is of such a “serious,” “obstructionist,” “extreme,” “aggravated,” “noisy, disorderly, and disruptive” nature that it is virtually or “wholly impossible to carry on” with the court’s proceeding, as per Illinois v. Allen, 397 U.S. 337, 338, 346 (1970)). In dicta, the Faretta Court also appeared to say or infer that civil pro se litigants in state court have an analogous federal constitutional right of This petition asks this Court to squarely reach and affirm what this Court earlier indicated about the federal constitutional right of a civil pro se state court litigant in the Faretta dicta. QUESTION #1. Is a pro se civil litigant’s right of self-representation in state court protected as a fundamental federal constitutional right subject to the strict scrutiny test under the United States First Amendment (Free Speech, Free Exercise, Petition Clauses) as incorporated by the Fourteenth Amendment? QUESTION #2. Is a pro se civil litigant’s right of self-representation in state court protected as a fundamental federal constitutional right subject to the strict scrutiny test under the United States Fourteenth Amendment (Due Process and Privileges and Immunities Clauses)?