Whether Florida's use of 'special counsel' to investigate and present mitigation and its requirement of a presentencing investigation report to provide mitigation for the trial court, all contrary to the expressed objection of a pro se defendant, violate both Faretta v. California, 422 U.S. 806 (1975) and the Sixth Amendment to the United States Constitution

QUESTION PRESENTED Whether Florida’s use of “special counsel” to investigate and present mitigation and its requirement of a presentencing investigation report to provide mitigation for the trial court, all contrary to the expressed objection of a pro se defendant, violate both Faretta v. California, 422 U.S. 806 (1975) and the Sixth Amendment to the United States Constitution. ii