Does a waiver of counsel constitute a relinquishment of the right to effective assistance of counsel?

United States v. Dujanovic (9th Cir.1973) 486 F.2d 182, cited by the People, fails to support this contention. In Dujanovic, the defendant's conviction was reversed on the ground that the trial court had failed to make a sufficient inquiry into the defendant's capacity to decide whether to waive counsel. The court concluded there had been no valid waiver. In discussing the difficulties involved in Faretta proceedings, the court mentioned in dictum that obstreperous or disruptive actions of the defendant might "well stand as a voluntary relinquishment or forfeiture of the limited constitutional right to proceed pro se." (Id. at p. 187.) The People draw comfort from this dictum and urge that defendant's actions constituted a forfeiture of the right to effective assistance of counsel.