Whether the Second Circuit Court of Appeals applied an incorrect standard in concluding that Petitioner knowingly and intelligently waived his Sixth Amendment right to counsel, even though the District Court never advised him of any specific risks and disadvantages of self-representation

QUESTION PRESENTED 1. Whether the Second Circuit Court of Appeals applied an incorrect standard in concluding that Petitioner knowingly and intelligently waived his Sixth Amendment right to counsel, even though the District Court never advised him of any specific risks and disadvantages of