What is the test for a defendant to validly waive their right to counsel?

California, United States of America


The following excerpt is from People v. Mone, G055694 (Cal. App. 2019):

For a defendant to validly waive the right to counsel, two distinct conditions must be satisfied: the defendant must be mentally competent to make the decision, and the waiver of counsel must be knowing and voluntary. (Godinez v. Moran

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