Does a criminal defendant have to waive their right to counsel to effect a valid guilty plea?

MultiRegion, United States of America

The following excerpt is from Sanchez Rubio v. Lewis, 108 F.3d 339 (9th Cir. 1997):

1 The Court in Carnley v. Cochran, 369 U.S. 506, 516, 82 S.Ct. 884, 8 L.Ed.2d 70 (1962), had already required that criminal defendants knowingly and voluntarily waive their right to counsel in order to effectuate a valid guilty plea.

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