Whether an indigent criminal defendant's waiver of trial counsel requires a clear and unequivocal request to proceed pro se

QUESTION PRESENTED The federal courts of appeals are about evenly split over whether an indigent criminal defendant’s waiver of trial counsel requires a clear and unequivocal request to proceed pro se. That important Sixth Amendment question has been percolating in the lower courts for decades, but no consensus has emerged. The deep and intractable circuit split appears likely to persist until this Court settles the matter. The question presented is whether, under the Sixth Amendment, a trial court may find that an indigent defendant’s request to fire his appointed lawyer, without clearly and unequivocally electing to represent himself, may waive the right to trial counsel.