Benjamin Adams v. Midge Carroll, Warden

KOZINSKI, Circuit Judge:

A criminal defendant’s assertion of his sixth amendment right to self-representation must be knowing and intelligent, Faretta v. California, 422 U.S. 806, 835, 95 S.Ct. 2525, 2541, 45 L.Ed.2d 562 (1975), timely and not for the purpose of delay, United States v. Smith, 780 F.2d 810, 811 (9th Cir.1986) (per curiam), and unequivocal, Armant v. Marquez, 772 F.2d 552, 555 (9th Cir.1985), cert. denied, 475 U.S. 1099, 106 S.Ct. 1502, 89 L.Ed.2d 902 (1986). This case presents a question concerning the last of these requirements: Is a request to proceed without counsel…